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					Action Agenda Public Comment Matrix (May 15, 2012)

Commenter        Comment Topic Area
Name/Org         er
                 Category
DNR              State    Ag Runoff
                 Agencies



DOH              State    Ag Runoff
                 Agencies

East Jefferson   Interest   Ag Runoff
Watershed
Council

Ecology          State    Ag Runoff
                 Agencies




Environmental Interest      Ag Runoff
Caucus
EPA             Fed Gov    Ag Runoff




Joint letter   Counties Ag Runoff
from WSAC,
Environmental,
and
WSDAicultural
Caucus




Pacific Coast   Interest   Ag Runoff
Shellfish
Growers
Association



ReSources for   Interest   Ag Runoff
Sustainable
Communities
WSCC   State    Ag Runoff
       Agencies




WSDA   State    Ag Runoff
       Agencies
Ecology       State    Appendices
              Agencies




Environment   Other       Appendices
Canada        Gov or
              Special
              Districts




Northwest     Interest    Appendices
Straits
Commission
Strait ERN   Interest   Appendices
DFW           State    Biodiversity
              Agencies




DNR           State    Biodiversity
              Agencies


Environment   Other       Biodiversity
Canada        Gov or
              Special
              Districts
Environmental Interest   Biodiversity
Caucus




EPA            Fed Gov   Biodiversity




King County    Counties Biodiversity



Seattle        Cities    Biodiversity




USFWS          Fed Gov   Biodiversity
DFW   State    Cleanup
      Agencies




DNR   State    Cleanup
      Agencies
DOH   State    Cleanup
      Agencies
Ecology        State    Cleanup
               Agencies




Environmental Interest   Cleanup
Caucus
EPA              Fed Gov    Cleanup




Friends of the   Interest   Cleanup
Earth




Hood Canal       Interest   Cleanup
Coordinating
Council
King County     Counties Cleanup




Lincoln Loehr   Citizen    Cleanup




ReSources for   Interest   Cleanup
Sustainable
Communities




Strait ERN      Interest   Cleanup
WSCC       State    Cleanup
           Agencies




American   Interest   Climate
Rivers                Change
DFW            State    Climate
               Agencies Change




Environment   Other       Climate
Canada        Gov or      Change
              Special
              Districts
Environmental Interest    Climate
Caucus                    Change
EPA          Fed Gov   Climate
                       Change




Ken Dickey   Citizen   Climate
                       Change
Makah         Tribe      Climate
                         Change


Nature        Interest   Climate
Conservancy              Change




Northwest     Interest   Climate
Straits                  Change
Commission



Phil Wolff    Citizen    Climate
                         Change




Seattle       Cities     Climate
                         Change
Sierra Club     Citizen   Climate
Postcards                 Change




Sirra Club Form Citizen   Climate
Letter                    Change




Sirra Club Form Citizen   Climate
Letter                    Change
Various Citizens Citizen    Climate
                            Change




Environmental Interest      Eeelgrass
Caucus



Pacific Coast    Interest   Eeelgrass
Shellfish
Growers
Association


DFW              State    Eelgrass
                 Agencies


DNR              State    Eelgrass
                 Agencies
DNR             State    Eelgrass
                Agencies




Environment     Other       Eelgrass
Canada          Gov or
                Special
                Districts

EPA             Fed Gov     Eelgrass




Northwest       Interest    Eelgrass
Straits
Commission




Resources for   Interest    Eelgrass
Sustainable
Communities
Environment      Other       Executive
Canada           Gov or      Summary
                 Special
                 Districts




Environmental Interest       Executive
Caucus                       Summary




Friends of the   Interest    Executive
Earth                        Summary
USFWS    Fed Gov    Executive
                    Summary




WRIA 8   Interest   Executive
                    Summary




AWB      Interest   Floodplains




BIAW     Interest   Floodplains
Burlington       Cities   Floodplains




City of Bellevue Cities   Floodplains
COM   State    Floodplains
      Agencies
DFW            State    Floodplains
               Agencies




Environmental Interest   Floodplains
Caucus
EPA           Fed Gov    Floodplains




King County   Counties Floodplains




MBA           Interest   Floodplains
NOAA Fisheries Fed Gov   Floodplains




RCO           State    Floodplains
              Agencies
Renton    Cities   Floodplains




Seattle   Cities   Floodplains



Seattle   Cities   Floodplains
Stillaguamish   Tribe      Floodplains




Strait ERN      Interest   Floodplains




Upper Skagit    Tribe      Floodplains
WSAC Coastal   Counties Floodplains
Caucus




American       Interest   Flooplains
Rivers
WSCC   State    Flooplains
       Agencies




DNR    State    Forest
       Agencies Runoff
Ecology        State    Forest
               Agencies Runoff


Washington     Interest   Forest
Watershed                 Runoff
Restoration
Initiative




DFW            State    Freshwater
               Agencies




Environmental Interest    Freshwater
Caucus
EPA             Fed Gov    Freshwater




ReSources for   Interest   Freshwater
Sustainable
Communities




Seattle         Cities     Freshwater




Seattle         Cities     Freshwater
Stillaguamish   Tribe      Freshwater




Strait ERN      Interest   Freshwater




Upper Skagit    Tribe      Freshwater




WSCC            State    Freshwater
                Agencies




AWB             Interest   Funding
DNR            State    Funding
               Agencies




DOH            State    Funding
               Agencies




Doug Hennick   Citizen   Funding
King County    Counties Funding




Mukilteo       Cities   Funding


Point No Point Tribe    Funding
Treaty Council




Seattle        Cities   Funding
South Central   Interest   Funding
Action Area
Caucus Group




Washington      Interest   Funding
Farm Bureau




WRIA 8          Interest   Funding
WRIA 9           Interest   Funding




Anonymous        Citizen    General




Association of   Cities     General
Washington
Cities
AWB    Interest   General




BIAW   Interest   General
Burlington       Cities   General




City of Bellevue Cities   General
DFW   State    General
      Agencies
DNR   State    General
      Agencies




DOH   State    General
      Agencies
Donald Russell Citizen   General




Ecology        State    General
               Agencies
Ecology -      State    General
Hershman       Agencies
Marine Fellow;
MSP Related
Elements




Environment   Other       General
Canada        Gov or
              Special
              Districts
Environmental Interest   General
Caucus




EPA            Fed Gov   General
Friends of       Interest   General
Farms and
Forests




Friends of the   Interest   General
Earth




Hood Canal       Interest   General
Coordinating
Council




Johannes         Citizen    General
Litooey
Joint letter   Counties General
from WSAC,
Environmental,
and
WSDAicultural
Caucus




Karl Spees    Citizen   General




Kathleen      Citizen   General
Herrmann



Keith Olson   Citizen   General
King County     Counties General




Kitsap County   Counties General




Lincoln Loehr   Citizen   General
Lummi   Tribe      General




Makah   Tribe      General




MBA     Interest   General
MBA        Interest   General




Mukilteo   Cities     General
Nature         Interest   General
Conservancy




NCAA ECB       Interest   General
Representative
NOAA Fisheries Fed Gov    General




Northwest Pulp Interest   General
and Paper




Northwest      Interest   General
Straits
Commission
NWIFC   Tribe   General
Pacific Coast   Interest   General
Shellfish
Growers
Association




Parks           State    General
                Agencies
Pete Haase   Citizen   General




Phil Wolff   Citizen   General
Pierce         Counties General




Point No Point Tribe    General
Treaty Council
Puget Sound    Other       General
Conservation   Gov or
Districts      Special
               Districts




Puget Sound    Other       General
Regional       Gov or
Council        Special
               Districts
Puget         Interest   General
Soundkeeper




RCO           State    General
              Agencies
Renton          Cities     General




ReSources for   Interest   General
Sustainable
Communities
SCC       State    General
          Agencies




Seattle   Cities   General
South Central   Interest   General
Action Area
Caucus Group




Strait ERN      Interest   General




Susan           Citizen    General
Macomson
Upper Skagit   Tribe     General




USFWS          Fed Gov   General
Various Citizens Citizen   General
Washington    Interest   General
Farm Bureau




Washington    State    General
Sea Grant     Agencies




Wild Fish     Interest   General
Conservancy
WRIA 16   Interest   General




WRIA 8    Interest   General
WRIA 9         Interest   General




WSAC Coastal   Counties General
Caucus




WSDA           State    General
               Agencies
East Jefferson   Interest   Hood Canal
Watershed
Council




Environmental Interest      Hood Canal
Caucus




FORTERRA         Interest   Hood Canal




Hood Canal       Interest   Hood Canal
Coordinating
Council
Hood Canal    Interest    Hood Canal
Environmental
Council




Hood Canal     Interest   Hood Canal
Salmon
Enhancement
Group
Jefferson     Counties Hood Canal
County Board
of
Commissioners




Katy Isaksen   Citizen   Hood Canal
Lower Hood   Interest   Hood Canal
Canal
Watershed
Coalition




Phil Wolff   Citizen    Hood Canal
Point No Point Tribe   Hood Canal
Treaty Council




Port Gamble    Tribe   Hood Canal
S'Klallam
WRIA 16   Interest   Hood Canal




BIAW      Interest   Instream
                     Flows




DFW       State    Instream
          Agencies Flows
East Jefferson   Interest    Instream
Watershed                    Flows
Council




Environment      Other       Instream
Canada           Gov or      Flows
                 Special
                 Districts


Environmental Interest       Instream
Caucus                       Flows
EPA             Fed Gov    Instream
                           Flows




King County     Counties Instream
                         Flows




Renton          Cities     Instream
                           Flows




ReSources for   Interest   Instream
Sustainable                Flows
Communities
Seattle         Cities     Instream
                           Flows



Stillaguamish   Tribe      Instream
                           Flows




Strait ERN      Interest   Instream
                           Flows




Washington      Interest   Instream
Water Trust                Flows




WRIA 16         Interest   Instream
                           Flows
DFW            State      Invasives
               Agncies




Ecology        State    Invasives
               Agencies




Environment   Other       Invasives
Canada        Gov or
              Special
              Districts
Environmental Interest    Invasives
Caucus
EPA       Fed Gov   Invasives




RCO       State    Invasives
          Agencies




Seattle   Cities    Invasives




WSDA      State    Invasives
          Agencies
Environmental Interest    Island
Caucus




EPA            Fed Gov    Island




Northwest      Interest   Island
Straits
Commission
American       Interest   Land
Rivers                    Developme
                          nt
AWB    Interest   Land
                  Developme
                  nt




BIAW   Interest   Land
                  Developme
                  nt
COM   State    Land
      Agencies Developme
               nt
DFW   State    Land
      Agencies Developme
               nt
DNR   State    Land
      Agencies Developme
               nt
Ecology       State    Land
              Agencies Developme
                       nt




Ecology -      State    Land
Hershman       Agencies Developme
Marine Fellow;          nt
MSP Related
Elements
Environment   Other       Land
Canada        Gov or      Developme
              Special     nt
              Districts




Environment   Other       Land
Canada        Gov or      Developme
              Special     nt
              Districts
Environmental Interest   Land
Caucus                   Developme
                         nt




EPA            Fed Gov   Land
                         Developme
                         nt
FORTERRA      Interest   Land
                         Developme
                         nt




Great         Interest   Land
Penninsula               Developme
Conservancy              nt
Joint letter   Counties Land
from WSAC,              Developme
Environmental,          nt
and
WSDAicultural
Caucus




King County     Counties Land
                         Developme
                         nt




Kitsap County   Counties Land
                         Developme
                         nt
MBA            Interest   Land
                          Developme
                          nt




Mukilteo       Cities     Land
                          Developme
                          nt
NCAA ECB       Interest   Land
Representative            Developme
                          nt




Parks          State    Land
               Agencies Developme
                        nt
Port Gamble   Tribe    Land
S'Klallam              Developme
                       nt




Renton        Cities   Land
                       Developme
                       nt
ReSources for   Interest   Land
Sustainable                Developme
Communities                nt




Seattle         Cities     Land
                           Developme
                           nt



Seattle         Cities     Land
                           Developme
                           nt
Seattle         Cities     Land
                           Developme
                           nt




Stillaguamish   Tribe      Land
                           Developme
                           nt




Strait ERN      Interest   Land
                           Developme
                           nt
Upper Skagit    Tribe      Land
                           Developme
                           nt
USFWS         Fed Gov    Land
                         Developme
                         nt




Washington    State    Land
Sea Grant     Agencies Developme
                       nt
Wild Fish     Interest Land
Conservancy            Developme
                       nt




WRIA 16       Interest   Land
                         Developme
                         nt
WSCC          State    Land
              Agencies Developme
                       nt




WSDA          State    Land
              Agencies Developme
                       nt




Washington    Interest   Land
Farm Bureau              Developme
                         nt
City of Bellevue Cities     Land
                            Devleopme
                            nt



Brakke           Citizen    Marine
                            Invasives
DFW              State      Marine
                 Agncies    Invasives




DNR              State    Marine
                 Agencies Invasives


Environmental Interest      Marine
Caucus                      Invasives

EPA              Fed Gov    Marine
                            Invasives


ReSources for    Interest   Marine
Sustainable                 Invasives
Communities
NOAA Fisheries Fed Gov   Marine
                         Species




BIAW          Interest   Marine/
                         Nearshore
Brakke           Citizen   Marine/
                           Nearshore




City of Bellevue Cities    Marine/
                           Nearshore



Commerce         State    Marine/
                 Agencies Nearshore
DFW   State    Marine/
      Agencies Nearshore
DNR       State    Marine/
          Agencies Nearshore




Ecology   State    Marine/
          Agencies Nearshore
Ecology -      State    Marine/
Hershman       Agencies Nearshore
Marine Fellow;
MSP Related
Elements




Environment   Other       Marine/
Canada        Gov or      Nearshore
              Special
              Districts
Environmental Interest   Marine/
Caucus                   Nearshore
EPA              Fed Gov    Marine/
                            Nearshore




Friends of the   Interest   Marine/
Earth                       Nearshore




King County      Counties Marine/
                          Nearshore
MBA        Interest   Marine/
                      Nearshore




Mukilteo   Cities     Marine/
                      Nearshore
NOAA Fisheries Fed Gov   Marine/
                         Nearshore




Northwest     Interest   Marine/
Straits                  Nearshore
Commission
Parks         State    Marine/
              Agencies Nearshore




Port Gamble   Tribe      Marine/
S'Klallam                Nearshore




PSP           Internal   Marine/
                         Nearshore
Renton          Cities     Marine/
                           Nearshore




ReSources for   Interest   Marine/
Sustainable                Nearshore
Communities
Seattle   Cities   Marine/
                   Nearshore




Seattle   Cities   Marine/
                   Nearshore
Stillaguamish   Tribe     Marine/
                          Nearshore




Upper Skagit    Tribe     Marine/
                          Nearshore




USFWS           Fed Gov   Marine/
                          Nearshore
Washington       State    Marine/
Sea Grant        Agencies Nearshore




Wild Fish        Interest   Marine/
Conservancy                 Nearshore




DNR              State    Marine/
                 Agencies Nearshore
                          Species
Environmental Interest      Marine/
Caucus                      Nearshore
                            Species




EPA              Fed Gov    Marine/
                            Nearshore
                            Species




Friends of the   Interest   Marine/
Earth                       Nearshore
                            Species



Northwest        Interest   Marine/
Straits                     Nearshore
Commission                  Species
ReSources for   Interest   Marine/
Sustainable                Nearshore
Communities                Species




USFWS           Fed Gov    Marine/
                           Nearshore
                           Species




DFW             State    Miradi and
                Agencies Target
                         Views
DNR   State    Miradi and
      Agencies Target
               Views




DOH   State    Miradi and
      Agencies Target
               Views
Ecology       State    Miradi and
              Agencies Target
                       Views




Environment   Other       Miradi and
Canada        Gov or      Target
              Special     Views
              Districts


Environment   Other       Miradi and
Canada        Gov or      Target
              Special     Views
              Districts
Environmental Interest    Miradi and
Caucus                    Target
                          Views




EPA            Fed Gov    Miradi and
                          Target
                          Views

Hood Canal     Interest   Miradi and
Coordinating              Target
Council                   Views




King County    Counties Miradi and
                        Target
                        Views
Lincoln Loehr   Citizen    Miradi and
                           Target
                           Views




Mukilteo        Cities     Miradi and
                           Target
                           Views

NOAA Fisheries Fed Gov     Miradi and
                           Target
                           Views




Pacific Coast   Interest   Miradi and
Shellfish                  Target
Growers                    Views
Association
Port Gamble   Tribe      Miradi and
S'Klallam                Target
                         Views




Seattle       Cities     Miradi and
                         Target
                         Views




Strait ERN    Interest   Miradi and
                         Target
                         Views

WRIA 16       Interest   Miradi and
                         Target
                         Views
Seattle        Cities    Miradi/Tar
                         get Views




DFW            State    Mitigation
               Agencies



DNR            State    Mitigation
               Agencies




Environmental Interest   Mitigation
Caucus
EPA            Fed Gov    Mitigation




Hood Canal     Interest   Mitigation
Coordinating
Council




NOAA Fisheries Fed Gov    Mitigation
Environmental Interest   North
Caucus                   Central




EPA            Fed Gov   North
                         Central


DFW            State    Oil Spills
               Agencies
DNR           State    Oil Spills
              Agencies



DOH           State    Oil Spills
              Agencies

Ecology       State    Oil Spills
              Agencies




Environment   Other       Oil Spills
Canada        Gov or
              Special
              Districts
Environmental Interest      Oil Spills
Caucus




EPA              Fed Gov    Oil Spills




Friends of the   Interest   Oil Spills
Earth
Makah           Tribe      Oil Spills




Northwest       Interest   Oil Spills
Straits
Commission

Parker          Citizen    Oil Spills
MacReady




ReSources for   Interest   Oil Spills
Sustainable
Communities

WSAC Coastal    Counties Oil Spills
Caucus
AWB   Interest   Prioritizatio
                 n




COM   State    Prioritizatio
      Agencies n
DFW   State    Prioritizatio
      Agencies n




DNR   State    Prioritizatio
      Agencies n
Ecology       State    Prioritizatio
              Agencies n




Environment   Other       Prioritizatio
Canada        Gov or      n
              Special
              Districts
Environmental Interest   Prioritizatio
Caucus                   n
EPA            Fed Gov    Prioritizatio
                          n




Hood Canal     Interest   Prioritizatio
Coordinating              n
Council
King County   Counties Prioritizatio
                       n




Mukilteo      Cities    Prioritizatio
                        n




Pierce        Counties Prioritizatio
                       n
Point No Point Tribe    Prioritizatio
Treaty Council          n




Renton         Cities   Prioritizatio
                        n




Seattle        Cities   Prioritizatio
                        n
Strait ERN       Interest   Prioritizatio
                            n




WSCC             State    Prioritizatio
                 Agencies n




Various Citizens Citizen    Priortizatio
                            n
DFW             State    Public
                Agencies Access




Environmental Interest     Public
Caucus                     Access




EPA             Fed Gov    Public
                           Access




ReSources for   Interest   Public
Sustainable                Access
Communities




USFWS           Fed Gov    Public
                           Access
DFW             State    Salmon
                Agencies




Doug Hennick    Citizen   Salmon




EPA             Fed Gov   Salmon




King County     Counties Salmon




Kitsap County   Counties Salmon
Lummi         Tribe      Salmon




Nature        Interest   Salmon
Conservancy




NOAA Fisheries Fed Gov   Salmon
NWIFC         Tribe      Salmon




Puget Sound   Interest   Salmon
Salmon
Recovery
Council
RCO             State    Salmon
                Agencies




ReSources for   Interest   Salmon
Sustainable
Communities




Seattle         Cities     Salmon
Seattle         Cities    Salmon


Stillaguamish   Tribe     Salmon




Upper Skagit    Tribe     Salmon




USFWS           Fed Gov   Salmon
Wild Fish     Interest   Salmon
Conservancy




WRIA 8        Interest   Salmon
WRIA 9        Interest    Salmon




Environment   Other       San Juan
Canada        Gov or
              Special
              Districts




Environmental Interest    San Juan
Caucus
EPA           Fed Gov     San Juan
BIAW             Interest   Section D




City of Bellevue Cities     Section D




COM              State    Section D
                 Agencies
DFW   State    Section D
      Agencies
DNR   State    Section D
      Agencies




DOH   State    Section D
      Agencies
Donald Russell Citizen      Section D




East Jefferson   Interest   Section D
Watershed
Council
Ecology -      State    Section D
Hershman       Agencies
Marine Fellow;
MSP Related
Elements
Environment    Other       Section D
Canada         Gov or
               Special
               Districts




Environmental Interest     Section D
Caucus




Environmental Interest     Section D
Caucus
EPA   Fed Gov    Section D




MBA   Interest   Section D
Northwest    Interest   Section D
Straits
Commission




PSP          Internal   Section D
Puget Sound     Interest   Section D
Ecosystem
Monitoring
Program
Steering
Committee




Renton          Cities     Section D




ReSources for   Interest   Section D
Sustainable
Communities
Stillaguamish   Tribe      Section D




Strait ERN      Interest   Section D




WSCC            State    Section D
                Agencies
DFW   State    Shellfish
      Agencies




DNR   State    Shellfish
      Agencies


DOH   State    Shellfish
      Agencies
Ecology        State    Shellfish
               Agencies




Ecology -      State    Shellfish
Hershman       Agencies
Marine Fellow;
MSP Related
Elements
EPA          Fed Gov    Shellfish




Northwest    Interest   Shellfish
Straits
Commission
Pacific Coast   Interest   Shellfish
Shellfish
Growers
Association




Washington      State    Shellfish
Sea Grant       Agencies
WSCC           State    Shellfish
               Agencies




Environment    Other       Skagit
Canada         Gov or
               Special
               Districts




Environmental Interest     Skagit
Caucus
ReSources for   Interest   Skagit
Sustainable
Communities




Seattle         Cities     Skagit
Skagit Climate   Interests Skagit
Science
Consotrtium




Upper Skagit     Tribe     Skagit




Environmental Interest     South
Caucus                     Central
Puget Sound    Other       South
Regional       Gov or      Central
Council        Special
               Districts
Seattle        Cities      South
                           Central




WRIA 8         Interest    South
                           Central
Environmental Interest     South
Caucus                     Sound




Paul Allen     Citizen     South
                           Sound
Pierce          Counties South
                         Sound




Environmental Interest     Stilly/
Caucus                     Snoho


EPA             Fed Gov    Stilly/Snoh
                           o




Lincoln Loehr   Citizen    Stilly/Snoh
                           o




Northwest       Interest   Stilly/Snoh
Straits                    o
Commission
American         Interest   Stormwate
Rivers                      r




BIAW             Interest   Stormwate
                            r




City of Bellevue Cities     Stormwate
                            r
DNR              State    Stormwate
                 Agencies r




DOH              State    Stormwate
                 Agencies r




East Jefferson   Interest   Stormwate
Watershed                   r
Council
Ecology        State    Stormwate
               Agencies r




Environmental Interest   Stormwate
Caucus                   r
EPA            Fed Gov    Stormwate
                          r




Hood Canal     Interest   Stormwate
Coordinating              r
Council
King County   Counties Stormwate
                       r




MBA           Interest   Stormwate
                         r




Parks         State    Stormwate
              Agencies r
Pierce        Counties Stormwate
                       r




Puget Sound   Other       Stormwate
Regional      Gov or      r
Council       Special
              Districts



Renton        Cities      Stormwate
                          r
ReSources for   Interest   Stormwate
Sustainable                r
Communities




Seattle         Cities     Stormwate
                           r




Stillaguamish   Tribe      Stormwate
                           r
Washington       State    Stormwate
Sea Grant        Agencies r

WRIA 16          Interest   Stormwate
                            r


WSCC             State    Stormwate
                 Agencies r




East Jefferson   Interest   Strait
Watershed
Council
Environment    Other       Strait
Canada         Gov or
               Special
               Districts




Environmental Interest     Strait
Caucus
Makah          Tribe   Strait




Point No Point Tribe   Strait
Treaty Council
PSP Strait ERN   Interest   Strait
Strait ERN      Interest   Strait




Kitsap County   Counties Strategic
                         Initiatives
Point No Point Tribe      Strategic
Treaty Council            Initiatives




AWB            Interest   Toxics
BIAW             Interest   Toxics




City of Bellevue Cities     Toxics




DNR              State    Toxics
                 Agencies
DOH              State    Toxics
                 Agencies




East Jefferson   Interest   Toxics
Watershed
Council
Ecology        State    Toxics
               Agencies




Environmental Interest   Toxics
Caucus
EPA   Fed Gov   Toxics
Friends of   Interest   Toxics
Farms and
Forests
Lincoln Loehr   Citizen    Toxics




MBA             Interest   Toxics
Northwest Pulp Interest   Toxics
and Paper




Northwest      Interest   Toxics
Straits
Commission
Parks          State    Toxics
               Agencies




Port Gamble    Tribe      Toxics
S'Klallam




Renton         Cities     Toxics
ReSources for   Interest   Toxics
Sustainable
Communities




Seattle                    Toxics




Seattle         Cities     Toxics
Stillaguamish   Tribe      Toxics




The             Interest   Toxics
Precautionary
Group




USFWS           Fed Gov    Toxics
Washington      Interest   Toxics
State Nursery &
Landscape
Association
(WSNLA)




WRIA 16         Interest   Toxics



WSDA            State    Toxics
                Agencies
NOAA Fisheries Fed Gov   Urban
                         Stormwate
                         r




Seattle       Cities     Urban
                         Stormwate
                         r
COM      State    Wastewate
         Agencies r




Craft3   Interest   Wastewate
                    r
DNR   State    Wastewate
      Agencies r
DOH   State    Wastewate
      Agencies r
Ecology        State    Wastewate
               Agencies r




Environmental Interest   Wastewate
Caucus                   r
EPA              Fed Gov    Wastewate
                            r




Friends of the   Interest   Wastewate
Earth                       r




Jack Rosling     Citizen    Wastewate
                            r
King County     Counties Wastewate
                         r




Lincoln Loehr   Citizen    Wastewate
                           r




Pacific Coast   Interest   Wastewate
Shellfish                  r
Growers
Association


Parks           State    Wastewate
                Agencies r
ReSources for   Interest    Wastewate
Sustainable                 r
Communities




Strait ERN      Interest    Wastewate
                            r



WRIA 16         Interest    Wastewate
                            r


Environment     Other       Whatcom
Canada          Gov or
                Special
                Districts
Environmental Interest      Whatcom
Caucus




EPA              Fed Gov    Whatcom




Friends of the   Interest   Whatcom
Earth
ReSources for   Interest   Whatcom
Sustainable
Communities




NOAA Fisheries Fed Gov     Working
                           Waterfront
                           s
Comment Matrix (May 15, 2012)

        Comment


        Page 196
        Please add eelgrass to the list of targets affected by agricultural runoff, as excessive nutrients can
        cause plant growth and low dissolved oxygen, both of which harm eelgrass beds.


        p.195 - Delete last sentence in 1st paragraph under “The Challenge.” It’s not true that nutrients close
        shellfish growing areas.


        C3 Agricultural Runoff
        P. 196 C3.1 EJWC supports the use of voluntary and incentive-based programs to achieve recovery
        goals. However, it is our understanding that voluntary programs such as CREP are underfunded. We
        suggest adding a near-term action to increase funding for voluntary and incentive-based programs
        such as CREP.
        C3: Agricultural Runoff
        C3.1 NTA 1; suggested change: “The State Conservation Commission and the departments of
        Agriculture , Ecology and Health should identify priority areas and resource impacts to target areas
        where implementation of fund voluntary incentive programs for rural unincorporated landowners,
        small-acreage landowners, working farms and nurseries can to complement regulatory efforts and in
        priority areas that where they can best contribute to Puget Sound protection and recovery.” Note:
        suggested change is to emphasize doing actions rather than identifying them.
        C3.1 NTAs 2 and 3: Suggest deleting as specificity on this work has not yet been clarified by the
        implementing agencies. The two remaining NTAs (above and below) are significant and will greatly
        help advance this work.
        C3.2 NTA 1 Suggest replacing current NTA (CAFO permit) with a near-term action on Whatcom
        County inspections. Possible language: “Ecology, in collaboration with the Departments of Health
        and Agriculture, will increase inspections in Drayton Harbor and Portage Bay / Nooksack River
        Watersheds. The inspections will focus on livestock operations affecting shellfish resources and areas
        with high nutrients.” Performance measure: number of inspections.
        Page 198. Agriculture regulatory programs for pollution (C3.2). Although ensuring compliance with
        regulations is a good start, the regulations themselves need to be strengthened. The action should
        be written to cover both regulatory improvements and compliance.
C3 (page 195, second paragraph, first sentence) - Since the focus is on agricultural lands, the first
sentence should be limited to agricultural areas and not include “rural” areas.

C3 (page 195, second paragraph, second sentence) - Need to add “and/or conservation practices”
after “apply best management practices”. BMPs do not equal conservation practices, and
conservation practices receive funding and should be mentioned.

C3 (page 195, third paragraph) - Replace the first sentence with the following: “Successful
implementation and adaptive management of conservation plans and/or BMPs, combined with
appropriate regulatory support, are critical to environmental protection”.

C3 (page 195, third paragraph) – Modify the second to last sentence to read, “These landowners can
be difficult to reach through education and technical assistance outreach programs because they
typically do not belong to any agricultural group or they are not represented by agricultural producer
groups”.

C3.1 (page196) - Please clarify whether the NTA refers to Ecology’s BMP standards or the
Conservation Districts practice standards. If referring to the conservation planning process, it is a
rigorous method of conservation planning to protect natural resources based on NRCS conservation
practice standards. The method is used by NRCS and conservation districts. Practice standards are
not BMPs. The conservation plan is a collection, or system of practice standards specifically designed
to protect natural resources on that particular farm.

C3.1 (page 196) - Modify the second sentence in the third paragraph to read, “CREP is a voluntary
program, but once the producer receives funding they must implement the practices. The program
helps farmers…”

C3.1 (page196) - Modify the first sentence in the fourth paragraph to read, “These incentive-based
programs are currently implemented in a voluntary manner – that is, the landowner seeks out the
From 2007 through last year’s Farm Services Agency for served as Coordinators for our respective
conservation district, NRCS, or passage of ESHB 1886 we information and assistance” We are not
caucus’ negotiating an agreement through the Ruckelshaus Center. As you know, our negotiations
resulted in the establishment of the Voluntary Stewardship Program that intends to assure the
viability of agriculture while protecting critical areas as defined by RCW 36.70A.030 (5).
These four Puget Sound counties adopted resolutions/ordinances to opt into VSP: Thurston, Mason,
San Juan, and Skagit.
In our review, there are some 30 Near Term Actions that are either directly or tangentially related to
the implementation of the Voluntary Stewardship Program. Thus, our request that a specific Near
Term Action be more clearly stated as follows:
“Support implementation, funding, and assistance to the Washington State Conservation
Commission and those Counties participating in the Voluntary Stewardship Program”.
Sub-Task C3.2 - Ensure compliance with regulatory programs designed to reduce, control or
eliminate pollution from workingfarms.
We request that PSP include the following specific action from the WSI into the Near Term Actions
for C3.2:
• Reduce pathogen and nutrient loading by improving manure management in those areas with PIC
programs by offering incentives to implement eligible agricultural best management practices
including livestock exclusion fencing, off-stream watering, and livestock feeding.

C3.1: There needs to be a follow-up program to ensure that farm plans are implemented. It is our
experience that often they are not. A small farm inspection program, similar to the requirements for
inspecting septic systems, should be implemented in watersheds that have high levels of fecal
coliform. (p. 196)
Strategy C, subtask 3.1
Target voluntary and incentive-based programs in ways that will best contribute to Puget Sound recovery.

NTA #1
The State Conservation Commission and the departments of Agriculture , Ecology and Health should identify priority areas and
resource impacts to target areas where implementation of voluntary incentive programs for rural unincorporated landowners,
small-acreage landowners, working farms and nurseries can complement regulatory efforts and where they can best
contribute to Puget Sound protection and recovery.

WSCC Comment: Support

Strategy C, subtask 3.1
Target voluntary and incentive-based programs in ways that will best contribute to Puget Sound recovery.

NTA #2
[Placeholder: The Department of Ecology, in collaboration with the Department of Agriculture and the Conservation
Commission will identify an approach to ensure best management practices achieve water quality standards.]

WSCC Comment: Support the placeholder

Strategy C, subtask 3.1
Target voluntary and incentive-based programs in ways that will best contribute to Puget Sound recovery.

NTA #3
[Placeholder: [WHO] will report on the effectiveness of incentive programs to achieve resource objectives, with a particular
focus on water quality standards. Participation will be sought from: PSP, Ecology, Agriculture, Health, the Conservation
Commission, Conservation Districts, Federal agencies, and Tribes.]

WSCC Comment: Support the placeholder but recommend having the Conservation Commission lead this effort. The
Commission is already evaluating the effectiveness of incentive programs to achieve salmon recovery objectives. This would
be a logical extension of that work and it falls within the Commission’s statutory authorities and duties.

Strategy C, subtask 3.2
Ensure compliance with regulatory programs designed to reduce, control or eliminate pollution from working farms.

NTA #1
Ecology will issue an updated CAFO permit in 2012.
Dairy Nutrient Management

Under C3.2, Ensure compliance with regulatory programs designed to reduce, control or eliminate
pollution from working farms, please include the following NTAs for WSDA’s Dairy Nutrient
Management Program:

C3.2 NTA 2
Implement recordkeeping regulation; finalize recordkeeping and penalty matrix rule. (WSDA)

C3.2 NTA 3
Conduct an inventory of all waste storage ponds in the Puget Sound regions;
identify facilities that are in need of a structural evaluation by an engineer; identify facilities that
need to improve or replace current operation and maintenance strategies, provide technical
assistance, and utilize compliance actions if necessary. (NRCS/WSDA)
Appendix F Acronyms and Abbreviations
- PBDE is incorrectly shown as PDBE

- The PBT definition should include “toxics” instead of “toxins.” We are aware that it is incorrect in
the title of the PBT Rule, but that would require rulemaking to correct.

References and Additional Resources
Page 313: Please add: Puget Sound Initiative Cleanup of Toxics in Port Gamble
http://www.ecy.wa.gov/programs/tcp/sites_brochure/psi/portGamble/psi_portGamble.html

Page 313: Please add: Puget Sound Initiative Cleanup of Toxics in Port Gardner Bay
http://www.ecy.wa.gov/programs/tcp/sites_brochure/psi/everett/psi_everett.html



EC’s original comment that there is no explicit upfront mention of the West Coast Governors
Agreement still stands (beyond what is in Appendix C, P. 476). Since British Columbia has signed on
to this Agreement, it is a great opportunity to capitalize on, as it has explicitly stated goals.

Appendix C, examples of ongoing collaboration with Canada (page 476) This overview of the PS
National Estuary Program Management Conference resembles proceedings which may already be
published. If not, a few updates should be made to the section on Canada as an interest based
organization and collaboration.

Transboundary Indicators -- Under the auspices of the SOC, the Transboundary Ecosystem Indicators
project was created to establish a common understanding of transboundary ecosystem priorities for
action. Since its inception, two transboundary indicator reports were published in 2002 and 2005 to
share knowledge on the health of the Puget Sound Georgia Basin. The US Environmental Protection
Agency (EPA) Region 10 and Environment Canada’s Pacific and Yukon Region are in the process of
updating these reports, expanding the suite of indicators and increasing its relevance to ecosystem
health including human wellbeing.

Environmental Cooperation Agreement -- This agreement was signed on May 7, 1992 by Mike
Harcourt, Premier of BC and Booth Gardner, Governor of Washington State in Olympia.

Puget Sound Management Conference p. 468 - (Add) Northwest Straits Initiative
Diagram of Management Conference p. 469 - (Add) Northwest Straits Initiative to Implementation
Section (as bubble with LIOs)
Appendix D: NTA Table
page 485 - A5.3 LNTA 2 Salmon Recovery Lead Entities
Suggestion: It would be informative to somehow cross reference the two floodplain restoration projects listed under A6.1
LNTA 2, namely the NOPLE Dungeness River Floodplain Restoration, Phase II and the Elwha
Engineered Log Jams, to strategy A5.3 within this table.

page 486 - A6.1 LNTA 1 Elwha River Ecosystem Recovery
Change Request: These three specific Priority Actions are already prioritized in the order shown, hence should be noted as
such using numeric bullets (i.e., 1, 2, and 3), not simple bullets, within this LNTA.

Change Request: List the "Elwha Fish Committee partners and others" as the Owners/Secondary Owners of this LNTA.

Change Request: Change the text for this Performance Measure to read the following: “Continuous weir operation (Priority
Action #1) and monitoring of salmonids for adults, juveniles, and smolts (Priority Action
#2) on the Elwha River”. Including the Priority Action #s here serves as a cross-reference to the full list of three Priority Actions
that are a part of this LNTA.

A6.1 LNTA 2 Salmon Recovery Plans
Suggestion: Within the two 3-Year Work Plans from the two Lead Entities (i.e., NOPLE and HCCC) operating within the Strait
are many important marine and nearshore and pollutant reduction actions. For this reason, it may be more appropriate to
move this LNTA#2 somewhere under strategy A9, the Action Agenda's Salmon Recovery Strategy. Alternatively, if this LNTA#2
remains under A6.1, it should be, at a minimum, specifically cross referenced somewhere under A9.

Change Request: List the "North Olympic Peninsula Lead Entity, Hood Canal Lead Entity, and their respective member
organizations" as the Owners/Secondary Owners of this LNTA.

Change Request - List the four specific Priority Actions as indented subbullets under the respective NOPLE and HCCC 3-year
work plans in order to show the 3-year work plan origin.

page 487 - A8.1 NTA 1 Instream Flow Rules (Soundwide - Ecology)
Change Request: Include a separate LNTA table entry here (and on document page 86) under A8.1 to fully represent the Strait
Instream Flow packaged LNTA (and associated Priority Actions) to adopt and/or
implement Instream Flow rules for WRIA 17, 18 (East and West) and 19. As written, this NTA from Ecology does not fully
encompass all of the 5 Priority Actions originally submitted by the Strait ERN to the Partnership in September 2011 as part of
the Strait ERN LIO Templates. Including a separate LNTA from the Strait ERN within this table would comprehensively
represent and emphasize the priority actions that are
currently either missing or underrepresented, namely the WRIA 18 East (DRMT) Stream Flow Improvements, WRIA 17 Sequim
A.10
Comment: There are close to 100 state candidates, could be that only 35 are in Puget Sound, but that seems low.
Recommended Edit: See species distribution by county to verify:
http://wdfw.wa.gov/publications/00165/2011_distribution_county.xls

A.10.1
Comment: Aquatic species recovery plans inaccurately referenced.
Recommended Edit: Please amend sentence as follows: “Existing aquatic species recovery plans include…"

Comment: The listed species are often associated with lost habitat relationships. This action agenda should focus on
conserving and protecting those habitat features including remaining old growth forest, oak woodlands and prairies. Similar to
the acquisitions and restorations identified earlier in the document this should include direct acquisition of the imperiled
habitats, restoration of degraded habitats and regulatory mechanisms to avoid logging or developing these same habitats.
Recommended Edit: The near -term actions should focus on conserving and restoring these habitats. In addition a mitigation
banking program for protection of the prairie habitats should be established

Comment: WDFW also protects , acquires and restores the habitat of species as well.
Recommended Edit: Add "Protects, acquires, and restores habitat" to list of WDFW On-Going Programs. Also Develop a more
consistent approach for including/ommitting on-going programs.

Comment: Recovery plan for sandhill crane has no actions in Puget Sound Basin.
Recommended Edit: Delete it from document.

Comment: WDFW may have management recommendations for 101 species but only 33 of those species exist in Puget Sound
Basin and only 2 of the 5 priority habitats exist in the Basin.
Recommended Edit: Update text.

A.10.1 - On-going programs
Comment: Technical assistance to local jurisdictions inaccurately characterized.
Recommended Edit: Delete bullet "Develop new and better databases…"; Replace with: WDFW puts a high priority on
providing good biological information to local planners and decision makers to improve their ability to administer the Growth
Management Act and other locally administered land use laws. (p. 41) WDFW will expand its efforts to help local governments
use “best available science” in protecting important habitat. This will be done by providing good habitat mapping products to
local planners and by working with them to ensure that their local GMA plans, as well as other local conservation programs
such as “conservation futures” and open space property tax incentives, address the Species of Greatest Conservation Need,
associated habitats, and conservation actions identified in the CWCS. (CWCS 2005, p. 253)
Pages 104 - 105
The same information on DNR financial and technical assistance programs appears twice.


P.100 The description of Spartina "… cord grass that severely disrupts the ecosystems of native
saltwater estuaries" could be improved as there are much better descriptions available.
P. 102 EC supports a shift away from single species management to ecosystem based management.
In addition to species at risk there should be a discussion of "keeping common birds common" and
the transboundary opportunities and work already underway through Bird Conservation Regions
(BCRs) and the Pacific Coast Joint Venture.
P. 103 The discussion of biodiversity strategies is useful.
P. 105 There is an opportunity to mention the Green Bylaws Toolkit in the discussion with
Biodiversity Conservation Toolbox for Land Use Planners.
Page 100. Protect and Restore the Native Diversity and Abundance of Puget Species (A.10). This
strategy should include a brief discussion of the new research (Seabird-fish research shows threshold
for danger http://www.thenewstribune.com/2012/01/01/1965290/seabird-fish-research-shows-
threshold.html) related to the interconnection between fish and birds, fish and orcas, etc. As this
new report has shown, fishing can have devastating effects on seabirds.
Page 101. Coordinating species recovery plans (A10.1). It is important that all recovery plans be
coordinated, not just the upland and freshwater species. We recommend that salmon, orca and
other plans be included on the list as they are all interconnected.
Page 102. Fish and Wildlife Action Plan (A10.1 NTA 1). This near-term action appears to be an
“ongoing program” and perhaps should be handled that way in the Action Agenda.
It is very encouraging to see the inset on page 100 discussing the link between climate change and
biodiversity; and to see a specific CC point (#6) included on page 102 for WDFW. Hopefully those
familiar with Preparing Washington for a Changing Climate can evaluate how well the strategy is
incorporated into the Action Agenda.

A10.1 NTA 2: “… implementation of restration projects…” replace with restoration.

In the neither the Upland and Terrestrial or Marine and Nearshore Sections is there explicitly
identified targets/objectives for the protection and restoration of wetlands and streams. These
aquatic ecosystem targets should be explicitly identified and addressed.


Plans,” only describes the work of WDFW. We recommend adding discussion of activities
undertaken by other entities—for example, the work of local governments to regulate construction
projects.
Ecosystem Restoration. The Action Agenda seeks to restore the health of Puget Sound ecosystem.
However, there are only limited references to ecology, and ecosystem principles, in the document.
The ecosystem recovery targets are almost all single species, and there is little or no reference to
ecological communities. The concept of biodiversity, which is key to ecosystem restoration and
recovery, is not really brought up anywhere in the document. The majority of large scale ecosystem
recovery efforts that have been developed in the United States, including the San Francisco Bay,
Chesapeake Bay, Everglades, Great Lakes, and Gulf Coast focus on improving biodiversity.

The present status of ecosystem “attributes” and “components” needs to be clearly described and
quantified. It is hard to determine where we should be going in terms of ecosystem recovery if we
don’t know where we are right now. A status and trends section on key ecological attributes, such as
old-growth forested area, impervious area, percentage of shoreline that has been hardened, should
be provided to identify how much biodiversity and habitat has been lost in the Puget Sound, and the
rate to which these are being lost under current conditions.

The U.S. fish and Wildlife Service (USFWS) is the lead federal agency for protecting and restoring
biodiversity in the Puget Sound, and has jurisdiction under the Endangered Species Act for all
the terrestrial and freshwater wetland section for upland bird species and waterbirds that are more
dependent on functional freshwater wetlands, swamps and marshes.

A10.1 NTA 1: Implementation of species recovery plans and creation of a Fish and Wildlife Action
Plan for Puget Sound would benefit from federal involvement from FWS and NOAA.
A10.1 NTA 2: It should be noted that FWS and NOAA also prioritize implementation of restoration
and recovery projects identified within species recovery plans.
A10.1 NTA 3: Coordination with FWS/NOAA should be encouraged or noted here.
TBD, possibly C11.5
Comment: The public supports control of pollution because of they cause harm to people and
organisms. Though the Pollution section is appropriately focused on reducing pollutants in Puget
Sound, it lacks any focus on identifying which pollutants are causing the most harm to organisms in
Puget Sound. Not all pollutants are equally damaging to organisms. Because there are more toxic
substances entering Puget Sound than we have resources to address, we should gather information
about the harm that those toxic substances cause, and focus our limited prevention and cleanup
resources on the most damaging pollutants. Unfortunately, this is an information gap that is
preventing us from taking this strategic approach.
Recommended Edit: Include an NTA that calls for focused research to improve our understanding
about which major pollutant in Puget Sound have the greatest effects on biota.

C.11.5.1
Comment: Because it is responsible for monitoring toxics in the ecosystem, add WDFW as a partner.
Recommended Edit: Add WDFW to the list of partners.


Page 256, Cumulative Water Pollution Impacts in Puget Sound
Please note that eelgrass is also a target to which water cleanup strategies are highly relevant.

Page 257
Please revise C.11.1 to say “Complete TMDL studies and implement TMDL cleanup plans based on
the studies, as well as other water cleanup plans for Puget Sound…..

Page 263
C.11.3.1 – The name for PSAMP has been changed to Puget Sound Ecosystem Monitoring Program.
*p.263, C11.3 new
We suggest creating two subsections in the swimming beaches write up: One for freshwater
swimming beaches, and one for marine swimming beaches. Suggest new text for freshwater beaches
follows:
Freshwater Swimming Beaches
Additional funding is needed to create and implement a freshwater swimming beach monitoring and
notification program in the Puget Sound region. Today, only 6 of 39 counties throughout the state
monitor bacteria at freshwater swimming beaches. These locally funded programs provide
information to the public regarding health at public swimming beaches. Over the past few years,
cities and counties have discontinued these programs due to lack of funding.

p.C11.3 NTA 1 - Suggest modifying NTA as follows: By 2014, the Departments of Ecology and Health
will develop a proposal for a coordinated monitoring and notification freshwater swimming beach
program for the Puget Sound region. Performance measures: Develop a proposal for a freshwater
beach assessment and monitoring program

p.263, C11.3 NTA 1 - Revise NTA: By 2014, the Departments of Ecology and Health will develop a
proposal for a coordinated monitoring and notification freshwater swimming beach program for the
Puget Sound region. Performance measures: Develop a proposal for a freshwater beach assessment
and monitoring program

p.263, C11.3, NTA 2 - Remove this NTA. The BEACH Program is already structured to address all
recreational users of Puget Sound. Participating counties works with the BEACH Program to select
highly used beaches for all recreational activities. The list is available year round for public comment.

New C11.3 NTA 2: Suggest a new NTA as follows: Ecology and DOH will develop a plan to conduct
pollution source surveys and correct pollution problems at marine beaches used for swimming,
surfing, diving and other recreational uses. Ecology and DOH will coordinate with local, state and
tribal programs that address point source and nonpoint source pollution to assure that activities are
not duplicative. Performance measures: Development and adoption of a plan for source corrective
C11: Pollution Cleanup
Pg 256: Paragraph 1, bullet 2; technical correction in “The Challenge”: “Ecology has been working to
clean up 1,4191,580 toxic-contaminated sites located within a half-mile of Puget Sound, including
150 contaminated sediment sites. As of December 2011, 664 of these sites have been cleaned up or
reported cleaned up by Through August 2010, Ecology, potentially responsible parties, and other
entities. have cleaned up acres, or 34 percent, of the contaminated sediments sites have been
cleaned up. tracked in Ecology’s contaminated sites data system.” Note: Discussing two different
types of sites here is confusing. The suggested revisions are meant to clarify and inform.

Pg 256: Paragraph 1, bullet 3; technical correction in “The Challenge”: Should add to the end of this
bullet “The SCI score for Bellingham Bay does not reflect sediment cleanup efforts that commenced
after this sampling was conducted.” Note: This SCI sampling was conducted before substantial
cleanup has occurred. As written, the reader is led to believe that cleanup has not been effective.

Pg 256: Paragraph 2, first sentence; technical suggestions in “The Challenge”: “This strategy is
focused on efforts to correct water quality and sediment quality problems related to toxic chemicals,
nutrients, and pathogens by diagnostic studies and targeted cleanup activities. Implementing
corrective actions to clean up impaired marine and fresh waters is essential for reducing the harm
from pollution in the Puget Sound ecosystem. Sub-strategies in this section include completing total
maximum daily load (TMDL) studies that serve as water column cleanup plans for water bodies,
completing Cleanup Action Plans to restore restoring and cleaning up contaminated upland and
sediment sites within and near Puget Sound…..” Note: A clear differentiation that TMDLs are cleanup
plans for the water column and Cleanup Action Plans are for upland and sediment cleanups needs to
be made throughout this document. Otherwise the reader may be led to think that a TMDL
addresses water, sediment, and upland cleanup.

C11.1: Suggest edits to text as follows (page 259): “Other Studies:
• South Puget Sound Dissolved Oxygen Study (The results from the study will determine if a TMDL, or
Page 257. TMDLs (C11.1). Unfortunately, Ecology has conducted few toxics-related TMDLs (and this
continues as can be seen from the listing of planned TMDLs in these pages). These should be
encouraged by the Partnership. In addition, it would be helpful if this text could include more
information about TMDLs that remain to be done (at least the total number) based on the current
303d List.
Page 259. Clean up contaminated sites within and near Puget Sound (C11.2). Efforts also need to be
made to adequately monitor formerly cleaned up superfund sites. For example, the former NW
Transformer Inc. site along the Nooksack River could still be a source of the high PCB levels found in
Cherry Point Herring.
Page 260. Dredged material disposal sites (C11.2). Dioxin is a major problem for the dredge
management program. In the past, dioxin has not been analyzed in a number of projects resulting in
dioxin-contaminated sediment being contributed to the Puget Sound disposal sites. We recommend
that the text for this action describe the need for dioxin analysis for all disposed material.
Page 265. Microplastics. We object to the topic of plastic being relegated to an emerging issue. We
have abundant evidence that plastics are a concern in Puget Sound and feel that plastics should be
On page 255, “Address and Clean Up Cumulative Water Pollution Impacts in Puget Sound,” under
“The Challenge” section, a brief overview of TMDLs in the Puget Sound basin would be helpful in
providing an understanding of the scope of the water quality challenge. The description of “the
challenge” in this section currently focuses on Ecology’s water quality index, which is helpful in that it
is from a long-term, systematic monitoring program, but it does not reflect the full scope of water
quality challenges (e.g., does not include toxics).

C11.1 (pages 257-259) - “Complete TMDL studies…to address water quality impairments.” There are
no near-term actions for this sub-strategy; work will focus on completing TMDLs. It is important to
remember that while TMDLs are highly valuable and important for strategizing on sources and
remedies for water quality impairments, they are not enforceable (except for discharge limits
included in NPDES permits for point sources). A possible near-term action might be for appropriate
organizations (e.g., Ecology, EPA, local organizations) to confer on incentives/binding mechanisms for
ensuring pollutant reductions strategies called for in TMDLs are actually implemented for high
priority TMDLs.

C11.2 (page 260) – The second to last sentence in the second paragraph, “The number of cleanups
that are completed each year has been declining over time, however”, needs to be clarified. It is
unclear whether this statement means that the number of cleanups for sites within one half mile of
Page 259. Clean up contaminated sites within and near Puget Sound (C11.2): Efforts also need to be
made to adequately monitor formerly cleaned up superfund sites. For example, the former NW
Transformer Inc. site along the Nooksack River could still be a source of the high PCB levels found in
Cherry Point Herring.

Page 267. Fix problems caused by existing development (structural upgrades; regular and enhanced
maintenance) (C2.3): Efforts should be made to replace creosote pilings nearby herring spawning
beds given their sensitivity to PAH’s. Incorporation of acute and chronic Herring bioassays developed
by Ecology need to be made part of all refinery NPDES permits. These studies need to be established
for daylight conditions given the impacts of UV enhanced toxicity.


In Section C11.1 “Complete TMDL studies and other necessary water cleanup plans for Puget Sound
to set pollution discharge limits and determine response strategies to address water quality
impairments” consider adding to the list of “Key Ongoing Program Activities” that the Hood Canal
Aquatic Rehabilitation Program is working to address the human contributions to low dissolved
oxygen problems in Hood Canal, using the scientific findings from the Hood Canal Dissolved Oxygen
Program and others, to develop and advance corrective actions.
• NTAs for sediment cleanup are not included and given their importance for addressing aquatic
health, should be. An NTA could be the insistence of protecting and restoring funding for site
cleanups under the Model Toxics Control Act (while it is mentioned under existing programs on pg
261, MTCA funds have been increasingly diverted away from toxic cleanups in recent years).
• The third bullet under “Emerging Issues and Future Opportunities”—the evaluation of other
contaminated sites for inclusion on the priority list under the Puget Sound Initiative—should be
considered a NTA as it may be achievable and appropriate in the short term.
• The discussion of Total Maximum Daily Loads (TMDLs) on pg. 258 should emphasize that without
sufficient funding, local governments may not be able to implement TMDLs completed by Ecology
and EPA. This is an especially important issue given that the proposed upcoming changes in the
water and sediment quality standards (as a result of the proposed fish consumption rates) are likely
to significantly increase the number of TMDLs throughout the region.
• The discussion of (Pollution Identification and Correction) PIC programs on pg. 263 is important, as
they are an effective means to address problems where waterbodies are impaired by nutrients,
pathogens and toxics. We recommend discussion highlight funding shortfalls with this program.

Page 257. C11.1 complete TMDL studies etc….

The second paragraph says

In Puget Sound, there are chronic hypoxia zones in Hood Canal, Budd inlet, Sequim Bay, and
increasingly in areas of Whidbey basin and Quarter Master Harbor.

We are not aware of such an increase in the Whidbey basin. Data for Possession Sound (PSS019) and
Saratoga Passage (SAR003) do not support a decrease for dissolved oxygen.

Page 262, C11.3 Restore and protect water quality at swimming beaches and recreational areas.

This section describes numerous activities that can contaminate water with bacteria yet it
completely ignores wildlife, particularly birds. See comments about pages 28, and 239-240.


C11.1, NTA: The NTA should include methods to remove the TMDL back logs. The fact that these
TMDLs have languished so long is not acceptable. In addition, there is no mechanism to ensure that
the goals of non-point source TMDLs are met. For example, virtually no progress has been made on
the 2000 Lower Nooksack River TMDL for fecal coliform. (p. 259)
C11.2, NTA: We suggest 2 NTA’s in addition to the work already ongoing. 1) An analysis of how
interim cleanups have been used in the past, including whether they have slowed or sped up the
pace of entire cleanup, and/or have influenced the cleanup decision. 2) Convening a stakeholder
group to make recommendations about how to better implement public participation and include all
stakeholders in cleanups, in the early stages. (p. 262)


page 265 - Emerging Issues and Future Opportunities
Suggestion: Either mention within this first text bullet or create a new "Local Strategies" insert to
highlight the fact that the Strait has identified "Toxic Source Reduction Programs" as one of the
additional 19 Strategic Priorities, including specific Priority Actions for Microplastics with the Port
Townsend Marine Science Center, as the project sponsor.
Strategy C, subtask 11.5
Develop and implement a monitoring and evaluation program.

NTA #1
PSP will work with Ecology, DNR, DOH, other key implementation agencies, and stakeholders for the
Action Agenda to develop a program for monitoring the effectiveness of activities to reduce water
pollution to Puget Sound and monitoring progress towards ecosystem recovery targets for water
quality. (This will be done through the activities described in the cross-cutting strategy D, Implement
a Coordinated, Integrated Ecosystem Monitoring Program.)

WSCC Comment: Support. Recommend adding the Conservation Commission working with
conservation districts.
Thank you for the opportunity to review and comment on the draft Puget Sound Partnership Action
Agenda, released on December 9, 2011. We appreciate all the work that the Partnership and its
partners have undertaken to update the Action Agenda and support many of the elements of the
Agenda. However, much work remains to be done to recover Puget Sound and the rivers that feed it
by 2020. We urge the Partnership to make a number of changes, as outlined below, and to
incorporate stronger measures and a clear path for funding and implementing the Agenda
throughout. In addition, it is imperative that the final Agenda address climate change adaptation
needs in a more comprehensive manner. We look forward to working with the Partnership now and
after the final Action Agenda is released to make implementation and recovery of Puget Sound and
its rivers a success.

Climate Change Pressures in Puget Sound:
The climate change discussion beginning on page 15 is a good start toward integrating a strong
climate adaptation strategy into the Action Agenda. The discussion rightly highlights the multitude of
impacts
of climate change on hydrology, including smaller snowpack, earlier runoff, lower summer
streamflows, and higher winter flows. The Action Agenda also identifies several steps to adapt for a
changing
climate and states that the final document will reflect an initial consideration of climate adaptation.

What needs to be added, however, is a discussion of how those changes – and the resulting
competition
between instream and out-of-stream water uses – can be mitigated through a number of actions
now. Ongoing studies on the regional impacts of climate change are important, but we already know
much of
what it will take to best adapt to the changes that are headed our way. In other words, we believe it
is unnecessary to wait for perfect predictions of future climate before undertaking actions that we
already
know will serve as bulwarks against a variety of pressures facing the Puget Sound basin.
Climate Change Comments
Overall, the climate change section is exceptionally weak, considering that the text indicates that the need to
address climate change was recognized in 2008, (four years ago), and considering the wealth of existing
publications and analyses that could be drawn upon. These include scientific reports on projected climate
impacts for Washington’s coastal areas, and various reports outlining potential adaptation strategies for marine
and coastal regions. The text also indicates that climate change will be incorporated in the next draft, but this is
the draft made available for agency review and it is difficult to assess and evaluate something that is not here.

The current narrative lays out some general guidance on climate adaptation and provides a bulleted list of
climate driven impacts to Puget Sound. It could do so much more. We need to move beyond simply describing
impacts and move to articulating the case for “so what?”. What will these impacts mean to the things we care
about? How will these projected climatic changes impact our ability to achieve our desired outcomes for
restoring Puget Sound? What are our primary functions and responsibilities in terms of restoring Puget Sound,
and how will climate affect those? Which decisions need to be informed by climate science? Which actions
will be most sensitive to climate change and should be modified accordingly? What criteria should we use to
make those determinations?

There is no reason not to begin now in terms of laying out a proposed adaptation framework and to identify
specific strategies. It is important to remember that adaptation is not rocket science, and much information
exists to inform actions today. For example, the interim TAG3 report (attached) prepared to inform the
statewide Climate Response Strategy contains a number of adaptation actions specific to marine and coastal
systems. It is also includes a list of projected impacts to marine and coastal habitats, the ecological
consequences of those impacts and how those ecological consequences might impact the delivery of ecosystem
services. Another reference document prepared for the Statewide Climate response Strategy compiles in a
narrative format a comprehensive list of observed and projected impacts of climate change on marine and
coastal systems and includes citations to existing scientific literature (available through the WDFW website). It
is disappointing that these documents apparently have not been consulted or drawn upon as references as the
EC’s original suggestion that cooperation on ways to protect existing conservation areas from sea level rise, and how to choose new ones,




Page 16. Climate Change.
 • The descriptions of potential climate change impacts and the overall concern is well articulated.
We are concerned, though, that specific strategies are not yet included in this draft and not sure how
public review will occur of those strategies/actions. We would like an opportunity to review these.
• Throughout the current draft of the Action Agenda there is an inadequate climate-change overlay
for expected impact on each indicator or target. Climate is only treated as a "cross-cutting" issue for
a few topics, including Flood Plains. We request that sub-strategies, like the 6th sub-strategy for
Flood Plains, be emulated across each of the key sections that cover Upland and Terrestrial, Marine
and Nearshore and Reduce and Control the Sources of Pollution in Puget Sound.
 • The Puget Sound Partnership is explicit about working with the Washington Climate Impacts
Group, which we applaud. However, there are many additional groups that should be included in this
discussion and analysis. We recommend looking into the Washington Connectivity Working Group
that is already thinking about how to increase opportunities for adaptation so that plants and
animals can survive changes in the climate by moving to more tolerable habitat. Our campaign has
focused on how to connect the Cascades to Puget Sound, which will be essential to protecting viable
populations of wildlife. More attention must be paid to the uplands, as they play a key role in
determining water quality, safeguarding migrating species, like salmon and they are the arena for
which we must confront some of the most difficult pressures, like human development and
population growth.
CLIMATE CHANGE
Re: Climate Change section – Page 73
Increased awareness of climate change in the Action Agenda:
It is very heartening to see an upfront section on climate change (CC) pressures in Puget Sound. This
information will bring the awareness of CC projection scenarios to all the strategies. The section
appropriately prioritizes changes by confidence and refers to all the adaptation work conducted so
far by the Department of Ecology (Preparing for a changing climate).
Likewise, involving the Climate Impacts Group (CIG) is an outstanding move. The CIG is at the
forefront of developing models and scenarios for Washington, especially downscaling models, and
the CIG is closely involved with other climate change adaptation efforts in our region.
There are many scattered references to the Washington State Climate Response Strategy. We agree
with that the recommendations therein should be included into the specific plans in the Action
Agenda. The effort to incorporate the Washington Climate Response Strategy into the Action
Agenda will likely be a key area of assistance by the CIG representative.
General Comments:
The document should discuss that the projection scenarios are on a longer timeframe than 2020.
The document could point out that these projections are on a 40 year timeframe.
The Action Agenda discussion could be bolstered by including a short paragraph on the nexus of CC
Adaptation and Mitigation to sustainability and the general concept of “no regrets” actions. The
idea of “no regrets” (or equivalent) would fit nicely into the guiding principles inset on Page 17.
CC pressures could be included in Step 2 (Gathering of information on near-term actions) to insure
that each of the 12 points are checked against the projection scenario changes.
Similarly (using the figure on page 120 for marine systems and nearshore armoring as an example), it
I have been reading your Action Agenda draft of 9 December 2011 and was happy to see the guideline "Use best
available science" (pg 17).

I was less than happy to see an unexpectedly low estimate of sea level rise.

From your Action Agenda, pg 16: "Global sea level is rising due to ocean thermal expansion and melting of land
ice. Sea level in the Puget Sound region is expected to increase 6 inches (range of 3 to 22 inches) by 2050 and by
13 inches (range of 6 to 50 inches) by 2100."

The climate system is a NON-linear system. Greenland ice core data indicates that changes in atmospheric and
ocean circulation can cause dramatic, sudden change in the world's climate and sudden change is the norm
rather than the exception. In particular, it appears that sea levels have risen in a number of periods by a foot
and a half a decade.

Quoting from a Scientific American Article (http://www.scientificamerican.com/article.cfm?id=ice-core-reveals-
how-quickly-climate-can-change) "... changes took place from one year to the next more or less", "Following this
abrupt shift, as much as 20 degrees Fahrenheit (10 degrees Celsius) of warming occurred over the subsequent
decades—a change that ultimately resulted in at least 33 feet (10 meters) of sea-level rise as the ice melted on
Greenland." This sea level rise is thought to have taken place over roughly 50 years.

The last time the earth was even 3 degrees F warmer, the sea level was about 82 feet (25 meters) higher than
today. [e.g. http://www.sciencedaily.com/releases/2008/01/080115102706.htm, references in Dianne
Dumanoski's book _The End of the Long Summer_]

Even given the tenuous assumption that the climate system stays within a linear range, NASA asserts "Global sea
level rose about 17 centimeters (6.7 inches) in the last century. The rate in the last decade, however, is nearly
double that of the last century." [http://climate.nasa.gov/evidence/]

A refereed report commissioned by the World Wildlife Fund expects "Sea level will rise more than 1 metre by
2100" [http://assets.panda.org/downloads/wwf_arctic_feedbacks_report.pdf, ARCTIC CLIMATE FEEDBACKS:
GLOBAL IMPLICATIONS, pg 13].
Page 17. Adapting for a Changing Climate. It is important to note the significant impacts to treaty
rights that can be caused by changes to fish migrations targeted tribal fishermen who are restricted
in the area they can fish.

~As noted in the draft document, climate change risks and challenges must be better addressed.
Climate change is one of the biggest threats to the long term health of people and nature in Puget
Sound. It affects every ecosystem recovery target in real and significant ways. Addressing this
overarching issue substantively in the AA will help ensure the document stands up to scrutiny and
becomes the credible recovery agenda we all hope it will become.

~Incorporate climate change as one of the priority cross-cutting strategies (see 2c above regarding
developing a suite of high level, cross-cutting strategies). Because the health of both people and
nature are vulnerable to climate change, it may be a great catalyst for affecting the level of change in
governance, society and action that will be required to recover Puget Sound. Whether this involves
flood districts or utilities joining floodplain restoration efforts in order to reduce the impact of
increased flooding or sedimentation in rivers, or communities strategically restoring tidal marshes to
increase storm protection services provided, climate change adaptation can be a catalyst to create
the non-traditional partnerships and multiple-benefit projects that are needed to recover Puget
ClimateClimate changeAction Agenda: p. 17 threats to the PS ecosystem. But it provides an
Sound. Change in the is one of the biggest
Northwest Straits Initiative proposes to take the lead in conducting community outreach on the issue
of ocean acidification, in northern Puget Sound. The Northwest Straits Commission can serve as the
touchstone to inform LIOs with or without an MRC.


Can you help me understand the following sentence which is located in the agenda ? Cross-cutting
issues for salmon recovery and climate change adaption integrated. The integration of the salmon
recovery plan is called out and initial climate change adaptation needs are identified. The climate
change adaptation work will be more fully articulated in the final Final agenda? Final report?
Climate change – are you referring to cooler water and surface temps / more snow pack (recent NW
trend) or is this based on predicted long term global warming?




Climate Change. The lack of comprehensive inclusion of climate change in the draft Action Agenda
makes it difficult to fully assess the issue as it relates to the efforts of the Partnership. We’re pleased
the Partnership is working with the UW Climate Impacts Group. “..to set the Puget Sound region and
the Action Agenda on a path for adapting our work in the face of a changing climate”. However, the
wording seems to be a little off, in that PSP and UWCIG is not setting the Puget Sound region on an
adaptive path, but rather the Action Agenda. Setting the region on an adaptive path implies some
sort of multi-stakeholder process involving impacted and interested entities (including Seattle Public
Utilities) and we’re not aware of that happening.

On page 16, it notes some projected changes in snowpack which do not translate into one to one
changes instream flow. It would be helpful to clarify this so that readers aren’t left doing their own
extrapolation.
At the bottom of page 17, it says “…initial analysis of the Climate Impacts Group and the state
response strategy will inform this work.” Something along the lines of “as well as climate
assessments conducted and/or adaptation strategies developed by other governmental agencies,
including local government, in the Puget Sound region.” sound be added. If this is indeed a
partnership, it is important to build off of work that has already been done on this issue by others,
Severe flooding, summer drought and low steam flows, sea level rise, and stronger storms - these
climate change impacts threaten the health of Puget Sound and our region's way of life.

To mitigate these impacts, we call on you to strongly discourage conversion of working farms and
forests into impervious surfaces, limit development in floodplains and critical floodplain habitat, and
utilize ecosystem services and natural areas as buffers to help filter toxic storm-water to address
some of the worst impacts of climate change.

As we experience increases in water temperature, altered river and stream flows, loss of near-shore
inter-tidal zones, increased flooding and massive changes in precipitation, we realize that climate
change is upon us.

It is essential that the Puget Sound Action Agenda Revision takes climate change impacts into
account, preparing our community for the changes we are already feeling as well as the scenarios
scientists are warning us about. To prepare for climate change, we strongly suggest viewing all
relevant Puget Sound restoration and protection strategies and actions through the "lens" of a
changing climate. We must insist that decision makers consider the merit and value of every strategy
and near-term action in a real-world context, the context of a changing climate.

One way to accomplish this is to improve or amend the Prioritization Framework laid out in the draft
Action Agenda so that the Prioritization Framework takes climate change into account. Thus, adding
a climate-change lens to the Prioritization Framework would appropriately value near-term actions
that expand opportunities for climate-adaptation, C02 mitigation, or increase climate resilience.
Actions that expand protected areas, limit "non-climate"
stressors, facilitate climate-smart management, improve our reliance on natural systems or help
mitigate climate change through carbon sequestration should receive special added priority value, as
these are strategic tactics we recommend for confronting climate change.

As we experience increases in water temperature, altered river and stream flows, loss of near-shore
inter-tidal zones, increased flooding and massive changes in precipitation, we realize that climate
change is upon us.

It is essential that the Puget Sound Action Agenda Revision takes climate change impacts into
account, preparing our community for the changes we are already feeling as well as the scenarios
scientists are warning us about. To prepare for climate change, we strongly suggest viewing all
relevant Puget Sound restoration and protection strategies and actions through the "lens" of a
changing climate. We must insist that decision makers consider the merit and value of every strategy
and near-term action in a real-world context, the context of a changing climate.

One way to accomplish this is to improve or amend the Prioritization Framework laid out in the draft
Action Agenda so that the Prioritization Framework takes climate change into account. Thus, adding
a climate-change lens to the Prioritization Framework would appropriately value near-term actions
that expand opportunities for climate-adaptation, C02 mitigation, or increase climate resilience.
Actions that expand protected areas, limit "non-climate"
stressors, facilitate climate-smart management, improve our reliance on natural systems or help
mitigate climate change through carbon sequestration should receive special added priority value, as
these are strategic tactics we recommend for confronting climate change.
The following are individual comments added to the form emails submitted via Sierra Club. See "Via Sierra Club" link under public comments for a
list of who said what.

9. It is essential that the Puget Sound Action Agenda Revision amend the Prioritization Framework to take climate change impacts into account.
Decision makers must be held accountable for choices that do not take into account or strive to ameliorate conditions resulting from a changing
climate. I live and vote in Whatcom County. I have been working for almost a year now to stop the proposed Gateway Pacific Terminal Project to
transport huge amounts of coal by rail through Bellingham and to ship it in massive cargo ships to China to be burned. This project is just such a
one that would very adversely impact the Puget Sound and any decision makers that have a part in assenting to it should be prosecuted for
negligence: they will be guilty of health impacts from the burning and shipping of coal that actually kill people and they will be guilty of
contributing to global warming on such a massive scale that we will never be able to turn back.

10. We need to consider climate change and the changes that will profoundly change water systems, and people along those systems as well as
restoration of puget sound.

11. It does not matter who or what is responsible for the change in our climate. We should be factoring in climate change impacts relevant to
Puget Sound restoration and protection strategies. Decision makers must consider the merit and value of every strategy and near-term action in a
real-world context…Please consider all the options.

12. Since the political power in Washington won't acknowledge this problem in any significant way it falls to the local level to act. While we can't
change the weather (much) we do have to deal with what is coming and change is happening now. We need to be working in as many possitive
ways to protect what we can. Changes in our individual behavior from driving less to composting and recycling do help but we need local
agencies to act as well.

14. I stand with the Sierra Club in their message that we must prepare in as many ways as possible for the coming changes to climate. Please plan
in any way you can wisely determine will support our ecosystems. Thank you

15. I stand with the Sierra Club in their message that we must prepare in as many ways as possible for the coming changes to climate. Please plan
in any way you can wisely determine will support our ecosystems. Thank you

16. Climate change affects all of us.

17. Prevention/preparation is the cheapest and most effective approach. Anticipation, not just response to fix the present problem is essential,
thus the Puget Sound Action Agenda Revision. We need to approach all relevant Puget Sound restoration and protection strategies and actions
through the "lens" of a changing climate. Let science and best projections guide the approach. to facilitate climate-smart management.

20. Our weather in Puget Sound has changed over the almost fifty years I have lived here. The future will bring more changes so snow pack,
Page 149. Eelgrass (B6). This section should also call out nutrient loading that leads to excessive
phytoplankton growth as a fairly well known stressor on eelgrass and link eelgrass recovery target to
nutrient reduction targets both Soundwide and in certain key oceanographic basins with high
residence times or in the local plans with embayments known for poor flushing and blooms of
ulvoids.
Task B6 - Implement a coordinated strategy to achieve the 2020 eelgrass recovery target- We
strongly encourage PSP to review the Near Term Actions within this task. The current Action Agenda
does not adequately link actions that will achieve the recovery target of 20% more eelgrass by 2020.
Our understanding of the science relative to eelgrass abundance is that it is light limited. Key actions
that can help achieve this are reducing nutrient inputs which result in light blocking phytoplankton
blooms or by increasing the biomass of filter feeding organisms such as bivalves.

B.6
Comment: Why is B6 called out separately from B7?
Recommended Edit: Clarify why B6 deserves to have a whole strategy focused on a single species or
else roll into B7
The 2020 target for eelgrass is to increase the acres of eelgrass in Puget Sound by 20 percent from
the 2000 to 2008 baseline period - an increase from about 53,100 acres to about 63,700.
20% increase in eelgrass – A sample (not complete) target-based framework for the Puget Sound
Action Agenda
TIMEFRAME FOR BENCHMARKS

*see DNR 2020 Eelgrass document for details
Eelgrass
The ongoing actions and NTAs in Protect and Recover Eelgrass (B6) have been carefully reviewed by
our Nearshore Habitat group, and they find them to be very incomplete. For example, only the
activities by DNR are included. There is only one NTA identified to reach the strategy. The
fundamental oversight of the entire Action Agenda, namely that there are no linkages among the
different strategies, is reflected in the eelgrass section, where strategies or actions on pollution
control and water quality improvements, essential to eelgrass recovery, are not considered. We
request that for B.6.1 that the Partnership add back in as a near-term action that DNR shall convene
partners in state and local government, Tribes, the federal agencies and nongovernmental
organizations and business groups to develop a broad-based strategy to achieve the 2020 eelgrass
target.

*see DNR 2020 Eelgrass document for timeframe for benchmarks on effective eelgrass restoration
P. 150 Any discussion on workshops and consultation with experts
techniques should involve BC experts as well.
P. 151 In the objective to increase eelgrass, there is no mention of the two species. This is important,
as one species is native, while the other is non-native. Some people view the non-native species as a
threat, others do not.

B6 Protect and Recover Eelgrass - It might be useful to acknowledge the importance of addressing
and monitoring the effects of Zostera japonica (a Class C noxious weed) eradication using chemicals
on Zostera marina communities. The Washington Dept of Ecology is addressing chemical spraying of
Z. japonica through an NPDES permit. There is not scientific agreement, however, on it being a
problem as an invasive species or on its habitat value in nearshore areas.

This section should recognize the changes that may occur to eelgrass as a result of increasing acidity
and increasing temperatures. It should also acknowledge that there is on-going loss of eelgrass beds
that are not entirely understood.

p. 149 B 6.1
Ongoing Programs: (Add) Northwest Straits Initiative is well-positioned to provide the tools and the
resources resulting from over a decade of successful eelgrass surveys and mapping in 7 counties to
other parts of Puget Sound.
Near Term Action: (Add) Provide support to Northwest Straits Initiative to continue systematic
monitoring of eelgrass beds in 7 counties. Data will be compiled in GIS database and provided to
local and state permitting/planning agencies.
B6.1:
-General comment: In addition to evaluating eelgrass bed area, DNR should assess eelgrass bed
connectivity and shoot density in order to develop a more complete understanding of eelgrass bed
health.
-DNR’s ongoing programs include a focus on preventing new and retrofitted overwater structures
from negatively impacting sea grass beds. While this is indeed a human caused stressor on eelgrass
beds, this section fails to acknowledge other stressors on eelgrass beds that can be addressed by the
Puget Sound Action Agenda. Excessive nutrient loading also threatens eelgrass beds by accelerating
algal growth, which can limit light to the grasses. In addition, pollutants such as oil and herbicides
from commercial and residential runoff can damage eelgrass beds. Anchor sites for recreational
boats and commercial vessels can also influence eelgrass bed health, as anchoring can damage and
rip up eelgrass beds. We request that the strategy for eelgrass recovery incorporates a more holistic
management approach. (p. 150)
In addition, recent decisions that may permit the use of herbicides on japonica by shellfish growers
should be understood in light of their probable impact on native eelgrass. Immediate response to the
threat of herbicides should be included as an NTA.
Strategies, Actions, Science Questions, Targets and Goals There seems to be a nested structure of
terms used by authors of the reports. Increased consistency in how strategies, actions and questions
are described and referenced would allow readers to compare dependencies among questions,
actions and strategies. Examples:

• Science Questions (Table 1, Page 5-6) -- The "Proposed Priority Science Questions from 2011-2013"
are good strong questions whose answers may serve to support further Action Agenda items,
however according to the Science Plan, these are Actions, not questions. It is not clear from the
drafts whether the Science Questions/Actions would be answered in a process independent of the
Action Agenda, although answers to some of the Science Questions could be instrumental in
identifying or prioritizing near term actions. If Science Questions are to be addressed from 2011-
2013, there may not be much time left to complete protection and restoration actions proposed
during the same period.

• Strategies -- There is reference to strategies in the Executive Summary, Full Report and Science
Plan, however it seems that among the three drafts and even within a single draft, strategies refer to
different levels of information. Page 10 of the Executive Summary lists 3 broad subsections of
strategies and actions, table 4 of the Executive Summary lists 60 key strategies, and table 5 of the
Overall comment. The executive summary focuses on process but does not serve as a stand-alone
document that outlines (in brief) the path to recovery AND the two-year priorities. We recommend
that it be revamped to be more like an “outline for success.” A reader (such as a legislator!) should
be able to read this document as a quick read that tells the whole story, similar to the JLARC report
(i.e., to recover the health of Puget Sound we need to do xx strategies, we will know we have
recovered the health when these targets are met, we will fund it by doing xx, and in the next two
years the priority actions are xx).
 • Lack of cultural sensitivity in the intro paragraph. Also lack of clarity of the geographic scope.
Suggested language: From the lush forests and lofty mountains of the Cascades and the Olympics to
the dynamic, scenic waterways and coastlines, Puget Sound is a national treasure. The Sound AND
ITS WATERSHEDS support a remarkable diversity of fish and wildlife species, provides us with
drinking water, seafood, timber, a location for ports and marine industries, opportunities for outdoor
recreation, and a buffer from Pacific storms. The Sound IS INTEGRAL TO TRIBAL CULTURAL HERITAGE
AND its degradation puts Treaties at risk of being unable to support their WAY OF LIFE. Residents and
visitors alike are drawn to this beautiful and abundant ecosystem.

Page 7. Legislative. Legislative actions are highly incomplete. Either this section should be eliminated
(especially in the Executive Summary) or it should be significantly expanded. It is misleading to have
just these few items included.

Executive Summary. There needs to be better recognition of the co-management efforts underway
between Federal and Tribal governments. In addition, genetic diversity is an important part of
resilience that needs to be mentioned.
From Table 1: Proposed Priority Science Actions in Action Agenda Exec. Summary: You have done a
good job of highlighting environmental contaminants in the Action Agenda as a topic requiring
additional research and action. We would like to emphasize that the effects of environmental
contaminants need to be addressed with regard to protecting fish and wildlife resources themselves.
We feel the Action Agenda could emphasize this better. For example we know that spawning coho
salmon are adversely affected during their spawning life stage in some urban streams. We
recommend a few edits to better emphasize this in the Action Agenda:
Pg. 5 of the Executive Summary; Table 1; Toxics; first bullet: “Implement studies to ensure that
Washington State’s water quality standards and sediment management standards are protective for
allowing human and wildlife consumption of fish and other seafood.” We recommend adding: “and
protective of fish and wildlife resources themselves” to the end of this sentence.
Pg. 5 of the Executive Summary; Table 1; Runoff from the Environment; bullet 5: “Evaluate individual
and combined effects of commonly used pesticides and other toxins on salmonids, other fish, and
their foods.” Please consider adding the bold text.

Table 5 in the Executive Summary (p. 16) needs to be placed in better context. Explain how this table
was developed (seems to be a roll up of local priorities from the LIOs). It needs to be better
formatted, synthesized and summarized to be more understandable before it can be prioritized in a
meaningful way. It could be sorted by geographic area and/or topic. It should be better linked to
Table 4. Currently it reads too much like an uneven laundry list. The final prioritized list should be
much shorter and clearer than what is in Table 5 as potential actions.

P. 24 Near Term Actions Not Included in Priority Setting: First bullet says that local actions will not be
included in the priority setting because they have already been prioritized and incorporated into the
AA. This is confusing. Isn’t the Table 5 of potential Near Term Actions in the Executive Summary a roll
up of priorities identified at the local level? This needs to be clarified as does what is Table 5.

On p. 25, example criteria for prioritization: it is going to be difficult to use the same criteria for
programmatic actions like land use regulations as for site-specific restoration actions. PSP may want
to use some different criteria for site specific habitat actions versus programmatic actions. For
example under example criteria #1, by having the measure be the % an action would mitigate a
pressure, this criteria will likely be skewed to only Puget Sound wide programs ever being ranked
A5.1 – A.5.4: …regarding floodplain protection, restoration and flood hazard management.
We support floodplains being evaluated, particularly in light of the new FEMA maps for several
communities. It is important that as various subtasks are addressed that local government, business
and industrial interests and property owners, particularly those with working lands are involved in
setting the appropriate direction.

A.5.1, NTA 3 and A.5.5, NTA 2:
Legislation, rule amendment, and/or administrative change that would achieve the floodplain
pressure reduction target must include policy and strategy for replacing lost buildable land. It is
crucial that the Puget Sound region has the ability to accommodate future housing demands. As
agricultural lands expand outsides priority floodplain areas, the PSP should work to expand land for
housing and rural development. It is required by statute that the PSP address economic viability and
projected population growth as a part of any plan and availability of affordable housing is an integral
part of the region’s economic health.
Burlington, like many cities throughout the nation, was developed in a river floodplain and gradually grew into its present
boundaries, adjacent to the Skagit River. Similarly, Dike District 12’s levee system was developed over time, and protects the
city as well as a significant area of floodplain to the north and east of Burlington from smaller Skagit River floods. Both the City
and the Dike District have a fundamental interest in protecting the city from flooding so that the City may maintain its
economic viability, which is central to the quality of life of tens of thousands of Skagit County residents. It is the intent of the
City and Dike District to work hard to support this fundamental goal in the most environmentally responsible way attainable.

Many ongoing efforts are already underway: Burlington operates its Storm Water Utility consistent with the requirements of a
National Pollution Discharge Elimination System (NPDES) permit under the oversight of the



Washington State Department of Ecology. The City has budgeted $300,000 to develop a Comprehensive Management Plan
for Gages Slough, which will include a significant clean water component. Additionally, the City has developed a compliance
protocol for implementing the requirements of the FEMA flood plain biological opinion, which has been submitted to FEMA
for review.

Also, the City and Dike District 12 continue to provide strong support to the Corps of Engineers General Investigation of Skagit
River flooding. This investigation continues to provide valuable information regarding floodplain management, including a
recent important report detailing the importance of maintaining connection in the Sterling area between Sedro-Woolley and
Burlington, where hydraulic modeling indicates more than 50,000 cubic feet per second of water, and nearly 150,000 acre-feet
of water, will leave the system in a 100-year Skagit flood event. In addition, the City has taken legislative action annually over
the past 10 years to preserve a levee setback corridor between the three bridges adjacent to the City. Future levee setbacks in
this area provide the promise of additional habitat restoration in the future.

Dike District 12 is the largest Dike District in Skagit County, and is a partner in flood risk management, along with eleven other
dike districts and a number of drainage districts, all special purpose districts which deal with water and flood management
throughout the Skagit River watershed. These Districts have been developing and managing flood risks since 1897, and
provide protection to over 100,000 residents of the County. More importantly, it is fair to say that every drop of water which
flows through the Skagit River watershed and ultimately arrives in Puget Sound, passes through the various Skagit County Dike
Districts. Dike District 12 is the largest District and a leader in flood risk management for the entire County. There is also the
Skagit County Flood Control Partnership, consisting of a cooperative of five Dike Districts which coordinate flood risk
management activities in Skagit County.

Without these Dike Districts, and flood risk management provided, along with environmental and habitat enhancements, an
eventual catastrophic flood is inevitable. A disastrous flood will destroy everything in its path, including infrastructure, life and
property, environmental and habitat improvements and projects, and all types and ranges of activities done by others to
preserve and protect the environment, fish habitat, and clean water. There is nothing more destructive to habitat,
• Task 5.1 - Actions related to floodplain management and FEMA programs should be deferred until
pending legal actions are resolved.
A5.4 Protect and maintain intact and functional floodplains.

A5.4 NTA 2: Ecology, Commerce, and other interested state agencies will develop a strategy for and lead
effective state engagement with local governments in the next round of CAO updates on frequently flooded
areas.
Performance Metric: TBD

p. 69 Commerce would need additional budget and staff resources to effectively engage in this effort with
Ecology and other agencies. Ongoing efforts by local governments to address the federal Bi-Op’s Reasonable
and Prudent Measures to ensure program certification by FEMA will be the primary driver of this work locally.
Due to the new Voluntary Stewardship Program option being administered by the state Conservation
Commission, certain floodplains with existing agriculture may not be directly affected by local CAO updates, but
rather by state approved local stewardship programs with monitoring oversight.

p. 70 The following edit is needed: “As a public resource, fish are protected by state Forest Practice Rules which
require landowners to restructure fish barriers by 2016 in a way that allows unobstructed fish passage. The
program provides 75–100 percent of the cost of removing the barrier, with the funding provided varying based
on the quality of the habitat, number of salmon and trout species benefiting from the correction, and project
cost.”

Is the Family Forest Fish Passage Program (or are any of the other listed state incentive programs) currently
funded? If not, then the AA should state this to avoid creating false expectations of funding when it is
unavailable. It is also noteworthy that this Program only addresses small forestry operations, not agricultural
operations.

A5.5 NTA 2: The conservation districts, agricultural community, watershed planning groups, and local
jurisdictions will use the outputs from the characterization work (A5.1 NTA 1) to identify potential land swaps
(i.e., county land use and conservation districts) and identify candidate areas available to expand for agriculture
outside of priority floodplain areas by 2012.
Performance Metric: (Status of list) By 2012, potential land swaps and candidate areas available to expand for
agriculture are identified.
A.5 - Protect and Restore Floodplain Function: The Challenge
Comment: Concerned that there is still no definition of floodplain in this document. The working
group was struggling with the definition and PSP recommended putting this work off until the end. I
thought that a working definition had been created. The definition should include what is a
functioning floodplain and what floodplains are included in the 2020 target. Originally, the PSP only
wanted to include large river floodplains. The document should clarify.
Recommended Edit: Clarify definition of floodplain, and which river systems are included.

Comment: This background does not take into account urbanization which is a large component of
loss of floodplain function in the Puget Sound. The document uses the word "flood risk reduction
projects". This is really a broad term and its difficult to know what the term means. For example,
does it mean building levees or reduce development.
Recommended Edit: Identify urbanization as explicit threat/challenge to floodplain protection and
restoration. Clarify or change term "flood risk reduction projects".

A.5 - Protect and Restore Floodplain Function: The Challenge
Comment: The floodplain section really focuses on restoration of degraded floodplains. The Puget
Sound area most of the large river floodplains are already degraded and urbanized. I would suggest
focusing our energy on floodplains that are less degraded and developed.
Recommended Edit: We should focus on not destroying our intact floodplains by increasing
regulation and not allowing new levee construction, dams that would affect river-floodplain
connectivity, and not allowing development in the floodplain.

A.5.5 - On-going Programs
Comment: The NRCS programs are much larger than these and they are not referenced.
Recommended Edit: Add relevant NRCS programs to list of On-going Programs. Also, Develop a more
consistent approach for including/ommitting on-going programs.

Comment: Family Forest Fish Passage Program acronym is 3 Fs not 2
Page 61. Flood Control. While seemingly a semantic argument, the term “flood control” should be universally replaced with flood attenuation, flood risk management,
flood hazard management or similar. Flood control as we know it, besides being impossible, is necessarily at odds with salmon recovery and ecosystem restoration.
Page 64. Protect and Restore Floodplain Function – General Comment (A.5). It is unclear how the Partnership will achieve both restoration and protection of current
floodplain habitat. If only restoration is done, and protection is not, then there will be much restoration investment that results in no (or little) net gain in flood plain
function. The Partnership’s plain to meet the no additional loss standard is unclear. Providing clarity to what “no additional loss” means, and specific actions that address
this goal will be essential to meeting it. FEMA has not been sufficient in ensuring that communities live up to BiOp expectations, and thus the Partnership and others have
a role to play in ensuring compliance.
Page 64. Planning group (A5.1). This new working group should also include NWF as they have been a key stakeholder in the effort to address floodplains. Other groups
are also highly qualified: American Rivers or Wild Fish Conservancy, for example. Moreover, these terms already have definitions in the literature, including the Puget
Sound Partnership report referenced in this section, so convening such a large and unwieldy group to redefine them seems a waste of the Puget Sound Institute’s
resources.
Page 64. A5.1 NTA 1. “The Ruckelshaus Process” is not defined or referenced here.
Page 64. A5.1 NTA2 and 3. The findings of this data gathering exercise should be published in a report first, reviewed by the Partnership Science Panel and then outreach
messaging and the action plan referenced in NTA3 should be developed from the peer-reviewed findings of both reports
Page 69. Protect and maintain intact and functional floodplains (A5.4). Current status of FEMA BiOP is incomplete. Currently National Wildlife Federation has a pending
litigation against FEMA for not fully implementing the seven elements of the RPA. This litigation, in part demonstrates that FEMA is not in compliance with the BiOp. The
Partnership has a role to play in facilitating local municipal adoption of the seven actions to comply with the ESA. The second action to comply deals with mapping and
improving flood plain maps. Mapping flood plains is particularly challenging because of the problematic FEMA definition that is used to identify the flood plains. This
definition is solely aware of past projections and does not account for anticipated climate change.
The existing Model: FEMA Floodplain
• Area inundated by flood with 1% chance of being equaled or exceeded in any given year (100 year flood)
• Defined by FIRM (Flood Insurance Rate Map)
We recommend working with FEMA and others to address this definition problem, and encourage a definition that takes the ecological, biological, and geological
definitions into account.
We recommend the following model for defining floodplains:
Recommended Models: Ecological Floodplain
• Areas periodically flooded by lateral overflow of river or lakes
• Biota responds to change in environment
Geomorphic Floodplain
• Flat, depositional feature of river valley
• Adjoins river channel

To best define floodplains, we also recommend considering George R. Pess and Sarah A. Morley’s assessment in Monitoring Stream and Watershed Restoration, Chapter
6: Monitoring Floodplain Restoration: “River corridors are naturally dynamic and ecologically complex components of a watershed and often contain a disproportionately
high amount of the total regional biodiversity (Naiman et al. 1993; Ward et al. 2001). Unaltered river corridors have heterogeneous landscape features, dominated by
dynamic conditions, and exhibit scale-dependent biophysical patterns and processes (Ward et al. 2001). A prominent feature within river corridors is the floodplain
A5.6 NTA 1 will have a broad benefit across the entire Action Agenda. A CIG member on the Science
Panel will be extremely valuable, not only for floodplain protection and restoration strategies, but
for many other near-term actions (for example, consideration of the types of trees to plant in
riparian zones that will be resilient to air temperature increases in 40 years).

-A5.1, NTA 2 - The prospect of sea level rise must be part of this discussion.

-A5.4 NTA 3 – “[Placeholder for an NTA on effectiveness monitoring related to status and trends of
floodplains.] Performance standard TBD”. Before an effectiveness monitoring approach can be
developed, ‘floodplains’ wil need to be clearly defined, given that there are multiple possible
definitions. Federal agencies, State programs, hydrologists and local communities use different
definitions for ‘floodplains.’ Agreeing on the definition of floodplains in the context of the recovery
target should be the initial NTA, with the effectiveness monitoring and tracking following this step.

-A5.5 NTA 2 – “The conservation districts, agricultural community, watershed planning groups, and
local jurisdictions will use the outputs from the characterization work (A 5.1 NTA 1) to identify
potential land swaps and identify candidate areas available to expand for agriculture outside of
priority floodplain areas by 2012.” – While the characterization work would be helpful in identifying
• Strategy A.5.2 (pg 65-66) recommends a holistic cost-benefit analysis for floodplain projects. It is
worth noting that The Federal Emergency Management Agency (FEMA) is directed to do the same
thing under the National Flood Insurance Program (NFIP) Biological Opinion, and is working on a
revised benefit-cost analysis for FEMA programs that may be a good starting place for other
agencies.
• A key conflict between the NFIP and functioning floodplains is that land behind certified and
accredited levees is not considered part of the regulatory floodplain, and as such is not subject to
floodplain regulations. Land behind levees can still contain part of the floodplain, providing valuable
ecological functions worthy of protection. In places where levees are currently accredited, this
regulatory definition removes many of the tools for mitigating future impacts to ecologically valuable
land behind levees. Where levees have not been accredited, it creates pressure to achieve
accreditation to avoid the imperative to protect additional floodplain area. We suggest an NTA be
included to address this problem under A.5.2 “Protect and Restore Floodplain Function.” Specific
policy suggestions are: (1) if a levee is accredited, a jurisdiction should be required to mitigate for
the floodplain that is disconnected from the river; and (2) to change the NFIP so that some
regulation and insurance is still required on floodplain lands behind levees.
• Part of A.5.1, under A.5.1 (pg 65) calls for developing case studies of multiple objective projects by
Strategy NTA1 NTA 3:
Any legislative change, rule amendment and/or administrative change put in place to achieve the
floodplain pressure reduction target must include a strategy for replacing lost buildable land supply.
This strategy could include such steps as establishing minimum urban densities in our high-
population counties, eliminating building height restrictions and encouraging cluster development
flexibility in rural areas, to name a few. Just as we must protect our fully functioning floodplains and
restore them where it makes sense, it is critical that we ensure our ability to accommodate future
population growth and housing demand.
Strategy A.5.5, NTA 2:
Similar to the above comment, as we work to identify potential land swaps to expand agriculture
outside of priority floodplain areas, we should also engage in a process to designate land for housing
and rural cluster development. It is required by the enabling PSP statute that the Partnership
addresses economic viability and projected population growth as part of any plan.
Floodplains: A5.1 Improving data and information to accelerate floodplain protection, restoration and flood
hazard management. Traditionally, several factors have impeded floodplain recovery (and related salmon
recovery and water quality goals). These factors include a lack of public support, expense of restoration, and
uncoordinated agency goals and policies. At the local government level, loss of revenue from protected or
undevelopable lands also has inhibited floodplain protection.

Yet seemingly divergent floodplain management goals—flood damage prevention, control, clean water,
salmon—are not inherently at odds with one another. Those portions of the river corridor that present the
greatest risks to people (i.e., incur the most flooding and erosion) are often the same areas where salmon
habitat, water filtering wetlands, groundwater recharge and flood storage are most likely to occur. The Action
Agenda Update includes a proposal to convene a group to establish a working definition of floodplain, floodplain
functions, and frequently flooded areas. We do not believe that is a necessary action, as this information already
exists. Floodplains and frequently flooded areas are defined as locations that annually have a 1% chance of
inundation from the 100-year storm. Currently, federal, state, and local regulatory agencies use this definition
from the Federal Emergency Management Agency (FEMA). Further, floodplain functions are described
thoroughly in the scientific literature and agency publications.

In recent years, FEMA worked closely with local governments in Puget Sound to develop a multi-objective
approach to managing floodplains under the National Flood Insurance Program. We recommend the Partnership
and local governments review and reference that work rather than initiating the Action Agenda Update’s
proposed review of policies and programs by 2013. Similarly, rather than gathering data on public perception of
flood risk, we recommend the Partnership focus on public education about floodplain benefits and risks of
developing in flood-prone areas. A good example of an effective public communication campaign is the U.S.
Army Corps of Engineers’ (Corps) recent outreach to residents of the Green River valley about flood risks from
the Howard Hanson Reservoir in 2008 through 2011. The Corps emphasized that floodplains will flood even
when levees are fully functional, and flood risk is never negligible. This information is available as public
guidance at http://www.asce.org/.
Similarly, the Action Agenda needs to be clearer about the purpose of some ongoing RCO grant
programs and the strategies to which they are linked. For example, the Washington Wildlife and
Recreation Program (WWRP) is listed as an ongoing program related to the protection and
restoration of floodplains.

While floodplain protection in Puget Sound may be an incidental benefit of WWRP, it is not the main
purpose of the program and the performance data collected does not directly measure floodplain
protection.

If the draft Action Agenda will require data to be reported differently, then it will require significant
resources and time to meet those needs. I hope you will take into account the data that we can
provide and how it is currently collected. We will continue to work with your staff to establish clear
expectations about what data will be required and what RCO can provide.
A number of the NTAs address floodplain management and set forth different processes intended to
result in changes to federal and state laws and regulations. It is not clear how the current efforts to
respond to Federal Emergency Management Agency (FEMA) and the National Marine Fisheries
Service (NMFS) Biological Opinion (BiOp) will be affected by the NTAs or whether the NTAs will need
to change as a result.

NTA A.5.1 would improve data and information to accelerate floodplain protection, restoration and
flood hazard management. This is a large workload for local governments, especially with the
number of tasks proposed to be accomplished in 2012. The list of tasks and proposed completion
dates are unrealistic and will need to involve private land owners, citizens, and local jurisdictions. In
addition, the issues included may be affected by the lawsuit filed against FEMA by NWF, and by
other issues related to the clarification or the potential re-opening of the BiOp. Local governments
will need to participate in this NTA. Levee setbacks need to be evaluated on a cost-benefit basis
especially in the highly urbanized basins where significant economic development has occurred. The
proposed project to buy out businesses and require property for levee setbacks results in a
significant cost, in addition to local jurisdictional economic impacts resulting from lost jobs,
decreased property tax revenue and other revenues, and the displacement of businesses.

NTA A.5.3 would implement and maintain priority floodplain restoration projects. The cost of bridge
A5 Protect and Restore Floodplain Function
Comment: Priority, particularly for staff in our municipal watersheds and those implementing our
HCP.

A.5 Floodplain Restoration
General comment: Seattle is so developed, not all of the goals/metrics seem applicable or reasonable
in a highly developed, urban area. Regarding loss of floodplain function - redevelopment in our
floodplains is strictly regulated so we assume no further harm but not necessarily significant
improvement.
Page 64 at the bottom - it’s already 2012 so “by 2012” doesn’t work. These will need to be modified
to a later (or more specific) date.


A5.1 NTA1: Floodplain Policy Team
Comment: If this is beyond what is already in the WRIA salmon recovery plans and that process,
Seattle already has decision-making frameworks and prioritization efforts for all projects, not just
floodplain. A new prioritization method introduced from PSP would have to be coordinated with
what is already being used.

A5.1. NTA2: PSP will gather data on public perception of flood risks, floodplain function
Comment: If this has not already been done, any surveys of Seattle residents regarding flood risks
should be performed in close coordination with Seattle Public Utilities (SPU). We have outreach
efforts underway and concerns in particular communities and so we would need to work together to
assure the PSP effort would be productive.

A5.3. Implement and maintain priority floodplain restoration projects.
Comment: The title is misleading, given the near-term actions. Is this about floodplain projects, or
projects to repair or replace infrastructure? This makes a big difference and if the latter you need to
bring in transportation departments regarding roads and bridges. They determine that list of
projects. For example, SPU owns and maintains most of the stream culverts but even then all
A5 Protect and restore floodplain function – A5.1 Improve data and information to accelerate
floodplain protection and flood hazard management.

Of all the limiting factors identified in the Stillaguamish Chinook recovery plan, the floodplain and
the estuary are perhaps the most degraded when compared to historical conditions. These low
elevation fish habitats were primarily diked and drained for agricultural use. In recent years, rural
residential development has begun to encroach on the floodplain. This has coincided with increasing
peak flows, putting more people and infrastructure in harm’s way. While the Tribe is working to
acquire and restore floodplain and estuary habitats, we are facing political resistance as described in
A2.1. Without significant restoration of floodplain function, the recovery of Stillaguamish Chinook
will remain impossible.

There is no lack of data or information on the importance of floodplain function as salmon habitat,
but rather a lack of political will to protect and restore these lands. The rivers need a corridor to
shift and move, and behave like rivers once again. Lands must be purchased and protected, held in
conservancy by public, tribal, and private entities. Infrastructure must removed from in the
floodplain and further development prohibited. Without these measures, our salmon recovery
efforts will be incomplete.

We encourage the Puget Sound Partnership to utilize local knowledge when pursuing this strategy.
Many groups including local jurisdictions, NGOs and especially tribes have existing data that could be
useful to this effort.
page 61 - Local Strategies insert
Change Request: Add the following sentence: "Strait lists restoration of the Dungeness and Elwha
River floodplains as two of the highest priority specific actions for their Salmon Recovery LNTA."

page 68 - A5.3 LNTA 2
Change Request: Change this LNTA to reference, more generically,important floodplain restoration
projects across the Puget Sound. In addition to the projects already listed here for WRIA 8, 9, and 10,
include reference to other floodplain restoration projects, including those important to WRIA 18,
namely, the Dungeness and Elwha River floodplains. These WRIA 18 floodplain projects are two of
the highest priority specific actions within A6.1, Salmon Recovery, LNTA 2.


The Tribe agrees and supports the target of protecting and restoring floodplain functions. The no net
loss of function will be more meaningful once these values are identified as described in A5.1 NTA 1.
The Tribe would like to participate in future discussions surrounding this indicator due to its direct
relationship to improve non listed stocks as well as recovery of listed stocks. In addition the Tribe has
completed an inventory of hydromodified bank structures in the Middle Skagit, and found 5280 ft of
new rip rap structures since the last inventory was completed in 1998. These and 88 new submods
have been installed or placed in the landscape since the ESA listing of the 6 independent stocks of
Skagit Chinook. The Tribe is also expanding this inventory for the Upper Skagit and Sauk watersheds,
courtesy of funds from the EPA and Puget Sound Partnership. It is anticipated the Tribe will be able
to identify restoration projects before the entire Chinook spawning and rearing range is inventoried
for these impacts, and will look toward the PSP to implement these projects.
A number of NTAs address floodplain management and set forth different processes intended to
result in changes to federal and state laws and regulations. It is unclear how the current efforts to
respond to FEMA and the NMFS BiOp will be affected by these NTAs, or whether the NTAs will need
to change as a result. Local governments are very concerned about the current status of changes
required by the BiOp, and this is further confused by the recent lawsuit filed by the National Wildlife
Federation against FEMA. For these reasons, please proceed very carefully in how the Action Agenda
addresses floodplain management.

We strongly support the Action Agenda’s goal of no loss of healthy floodplains from the 2011
baseline and 15 percent of degraded floodplains restored or clearly on their way toward restoration
by 2020. Thi s goal is ambitious but achievable with a concentrated, well-coordinated regional effort.

We are concerned, however, that the draft Action Agenda section on floodplains focuses perhaps
too much on acquiring data and issuing reports, which while necessary to some degree may come at
the expense of meeting your worthy on the ground protection and restoration goals. We urge you to
rely, to the extent possible, on the expertise of flood management experts with King County, Pierce
County, FEMA, NMFS, tribes, and non-profit conservation organizations (including American Rivers)
in order to expedite information gathering and move onto implementation as quickly as possible.

With respect to the Army Corps’ levee vegetation policy (discussed on pp. 67-68 of the draft Action
Agenda), the final Action Agenda should be more specific with respect to the challenges posed for
Puget Sound levee managers by the Corps’ existing levee vegetation policies and how those
challenges appear likely to be compounded by the issuance of new policy guidance on this topic from
the Corps. The existing four inch variance is too inflexible to allow mature, native trees to remain on
levees where they benefit salmon without harming public safety. The forthcoming policy is likely to
make even retaining this inadequate variance more difficult. And, even if the “matrix” for a new
updated variance discussed at the recent regional roundtable is allowed by the Corps to go into
effect, we fear it will at least initially be too limited in geographic scope and perhaps its flexibility to
allow enough large vegetation to benefit most rivers in Puget Sound. Finally, the final Action Agenda
Strategy A, subtask 5.5
Protect, enhance, and restore floodplain function on forest and agricultural lands.
NTA #1
By 2013, Conservation Districts and Watershed Groups implement three pilot projects that
demonstrate ecosystem services markets associated with flood hazard prevention and agricultural
lands in floodplains.

WSCC Comment: Support

Strategy A, subtask 5.5
Protect, enhance, and restore floodplain function on forest and agricultural lands.
NTA #2
The conservation districts, agricultural community, watershed planning groups, and local
jurisdictions will use the outputs from the characterization work (A5.1 NTA 1) to identify potential
land swaps (i.e., county land use and conservation districts) and identify candidate areas available to
expand for agriculture outside of priority floodplain areas by 2012.

WSCC Comment: Support. The Commission could also be mentioned as providing support to these
local efforts by providing facilitation and other resources.

Strategy A, subtask 5.5
Protect, enhance, and restore floodplain function on forest and agricultural lands.
NTA #3
PSP, DFW, NOAA, NRCS and others will work with farming communities to implement the Skagit
Tidegate Fish Initiative, the Snohomish Sustainable Lands Strategy and other multibenefit
approaches that enable agricultural infrastructure improvements and/or provide regulatory certainty
Forest Runoff
DNR staff reviewing the Forest Runoff section were not able to find clear linkages between forest
runoff and the ecosystem conditions we would like to address by improving runoff. No target views
included forest runoff, and there are no results chains for forest runoff. The final Action Agenda
should fill this gap and establish these linkages.

Because these linkages with broader ecosystem conditions are not made, it is not clear why the
“Relationship to Recovery Targets” singled out targets for forest runoff. We agree with fresh water
quality as a related target, but shellfish bed restoration, reductions of toxics in fish, and marine
sediment quality are not based on established linkages. On the other hand, Chinook salmon, land
cover and development, and summer stream flows all have established linkages with forest runoff
yet were not included on the list of targets for this section.

More importantly, seven of the eight NTAs previously identified by DNR and Ecology as critical
actions in the next two years were moved from NTAs to ongoing programs. While they relate to
existing program implementation, they are unfunded activities. Due to the continuing state budget
cuts to Forest Practices, the program cannot implement these actions without new funding. Since
the Action Agenda will be used to prioritize funding for Puget Sound recovery, and with these new
actions removed, the state will not be funding new actions for improvements of forest runoff. This
puts us back into the status quo feedback loop, not on the path to recovery of Puget Sound.

C.4.1.1
Please change this NTA to read:
“DNR and Ecology obtain an independent performance review of the Forest Practices Adaptive
C4: Forestry Runoff
Please see attached Ecology comments that offer some edits in track/edit format for technical
clarity. Also in the attached are two new suggested NTAs for this section.

The members of the Washington Watershed Restoration Initiative, a coalition that is concerned
about sediment laden runoff from US Forest Service (USFS) lands, would like to thank you for the
opportunity
to comment on the draft Puget Sound Partnership Action Agenda Update.
We are pleased to see that you identify “surface runoff from forest lands” as a problem that needs to
be addressed. The draft Action Agenda recognizes that in order to achieve a reduction in the sources
of pollution that enter Puget Sound, contributions from forest lands are critical. The Washington
Watershed Restoration Initiative was begun four years ago, in part, to highlight the problems caused
by the oversized and deteriorating road network on Forest Service lands. As you noted, 60---65% of
the Puget Sound basin consists of forested lands (26% of the basin is in Federal ownership) with
roads that deteriorate more each year. Surface runoff from forest roads, stream crossings, road
ditches and road cuts often deliver excess sediment to streams impacting water quality and fish
habitat. Because of the work of our coalition and leaders such as Congressman Norm Dicks, the
Legacy Roads and Trails Remediation Program was created to provide much needed funding for
road/trail decommissioning and stormproofing projects. We appreciate the recognition of the
accomplishments from this program in the draft Action Agenda.
Although some progress has been made, the backlog of projects grows every year and with every
severe storm event. As the needs increase, the funding levels for the Legacy Roads and Trails
Remediation program have decreased. The draft Action Agenda does recognize these issues, yet
misses an opportunity to provide any near term actions or performance measures. Our coalition
A.6.1.1
Comment: WDFW not shown as owner even though the Performance Measure is “Continuous weir
operation and monitoring of salmonids (adults, juveniles, and smolts) on the Elwha River”.
Recommended Edit: WDFW should be ‘secondary owner’ or the Performance Measure is incorrect.

A.6.1.2
Comment: Suggests that WDFW will need to be prepared for consultation & other involvement. Any
room to add steelhead recovery needs into this?
Recommended Edit: Add steelhead recovery to recovery plan needs.

A.6.2
Comment: Prairies and oak woodlands are the most imperiled terrestrial habitats in western
Washington. New NTA needed.
Recommended Edit: A.6.2.1 WDFW to implement priority prairies and oak woodlands restoration
projects.

Page 76. Implement and Maintain Freshwater and Upland Restoration Projects. (A.6). This section is
confusing because it stands alone from A.8. Protecting and Conserving Freshwater Resources.
Restoration projects require sufficient freshwater flows in streams and rivers to support salmon
during all critical life stages, and that dependence should be underscored in the Action Plan.
Page 79. Urban restoration (A6.3). This text should be improved to include at least a few sentences
about the huge amount of work currently occurring in urban areas. In addition to planting native
vegetation, there are efforts to remove invasive species, remove bulkheads/regrade banks, set aside
portions of private lots for open space, plant trees, and daylight creeks.
Under A.6, it would be helpful to include language about climate change in the salmon recovery
plans so that the recovery plan goals are/will be resilient to climate change. This comment also
applies to restoration of forestlands, wildlife corridors and prairies (A6.2).

Top of page 77: replace “conversation” with “conservation”

Page 79, 2nd line: “… retrofitting existing the stormwater…” - rearrange or delete.


A6.3, General Comment: Climate change needs to be addressed when planning restoration projects
in freshwater and terrestrial ecosystems. For example, when a log jam is put in place in a stream or
river as part of a restoration project, projected changes to hydrological regimes from climate change
need to be considered. We can no longer ignore changes associated with climate change and need
to address such planning considerations in restoration projects. (p. 78)
A.6.3: This sub-strategy on urban restoration does not accurately describe the magnitude or extent
of urban restoration efforts. In addition to planting native vegetation, non-native invasive species
are being removed, trees are being planted, creeks are being day lighted, and more. The amount of
community and volunteer participation in these projects should also be mentioned. (p. 78)



Upper Watersheds. Attention to the floodplain areas is certainly very important and appreciated,
particularly by our staff who work in lower watersheds. However, the Action Agenda generally
ignores the upper areas of Puget Sound watersheds. Non-floodplain areas, including headwater
streams and rivers, are vital to steelhead, bull trout, and spring Chinook salmon (the most
threatened Chinook run-type in the Puget Sound). Headwater streams and rivers contribute the
largest overall area to a Puget Sound watershed, and provide some of the most important ecosystem
services, including water production, nutrient cycling, organic matter production (carbon cycling),
large wood production, and sediment retention. Protecting and restoring these areas is critical to
sustaining the health of all Puget Sound Ecosystems. Maintaining healthy headwater forest, stream,
and wetland ecosystems will be vital to moderating and adapting to the impacts of climate change in
the future.

The majority of upland and terrestrial areas in several Puget Sound watersheds, including the Skagit,
are in federal ownership. However, the only ongoing programs identified in the Action Agenda are
those administered by state agencies and tribes. The Action Agenda should be expanded to include
better integration with ongoing actions by federal land management agencies.

A6 Implement and Maintain Freshwater and Upland Restoration Projects

A6.1 Implement and maintain priority freshwater restoration projects
Comment: This is a priority for Seattle, both in and along our major urban creeks as well as in the
Cedar River, along Lake Washington, and in the Skagit, Tolt and Snohomish watersheds. Very
underfunded.

A6.3 Implement restoration actions in urban and suburban areas while balancing the need for these
areas to accommodate growth, density and infill development
Comment: Support as a high priority for Seattle. Very underfunded. Still, the item should reflect the
A6.2 Implement and maintain priority terrestrial restoration projects

Comment: Terrestrial restoration needs to be identified.
A6 Implement and maintain freshwater and upland restoration projects

We appreciate the strategies outlined in this section with the intent of encouraging restoration
projects for the benefit of salmon and wildlife habitat. Another strategy that we would like the
Partnership to include is the elimination or easing of match requirements for public money. We
understand that multiple funding sources show a commitment to the project. However, obtaining
two or more funding sources often delays a project and requires significant staff time that could be
better spent implementing additional projects. As an independent agency reporting directly to the
Governor, the Partnership is in a unique position to evaluate funding sources impartially and
recommend changes to this requirement directly to the Governor.


page 78 - A6.1
LNTA 2 Puget Sound Recovery Plans (NOPLE and HCCC)
Suggestion: Within the respective 3-Year Work Plans for the Strait's two Lead Entities are many
important marine and nearshore and pollutant reduction actions. For this reason, it may be more
appropriate to move this A6.1 LNTA#2 somewhere under strategy A9, the Action Agenda's Salmon
Recovery Strategy. Alternatively, if this LNTA#2 remains under A6.1, it should be, at a minimum,
specifically cross referenced somewhere under A9.
The Tribe has been engaged in a wide variety of elk enhancement projects, and although no near
term actions have been identified under A6.2 "Implement and maintain priority terrestrial
restoration projects pg. 78." The Tribe would like to acknowledge their priority of restoring terrestrial
ecosystems for the betterment of elk populations in the Skagit and South Fork Nooksack watersheds.
The Tribe has successfully worked with partners to develop and implement continuing elk habitat
enhancement and protection projects. The tribal priority is protection and restoration of terrestrial
ecosystems of elk.
Strategy A, subtask 6.4
Implement stewardship incentive programs to increase the ability of private landowners to
undertake and maintain restoration projects.
NTA #1
No near-term action identified

WSCC Comment: Recommend a near term action as follows: Conservation districts with the support
of the SCC will implement stewardship incentive programs in a manner to increase landowner
participation in the implementation of restoration projects.
Funding:
The draft Agenda states, “Increased financial capacity to implement ongoing and new actions in the
Action Agenda and the Biennial Science Work Plan is required to achieve recovery goals,” and that,
“Increased capacity can be achieved through new sources of funding….”

Until the entire prioritization and review process is complete, discussion of new funding sources is
premature. A call to increase the funding support for near-term actions, as well as the ongoing
actions, assumes the work needed to make such a determination has been completed. It obviously
has not. The assumption that new funding sources are needed is premature, especially given the
previous discussion in this letter regarding the uncertainty around prioritization of both near-term
and ongoing activities.

Moreover, the actions identified in the current draft Agenda do not indicate a price tag, so how does
the Partnership determine that new funding is needed?

According to a presentation by the Joint Legislative Audit and Review Committee, based on the 2011
audit of the Partnership, total Puget Sound restoration expenditures for fiscal year 2011 exceeded
$670 million. These expenditures represent the ongoing restoration, enhancement, and protection
activities around the Puget Sound. We reasonably expect as the Partnership reviews the current
Pages 295 - 299, Funding Strategy

The funding provided by federal, state, and local governments, while considerable, has never been
adequate to fully implement the various Puget Sound water quality management plans going back to
1986. The 2006 Puget Sound Partnership, in its final report to the Governor (December 2006) noted
that “based on the estimates of current unmet needs, achieving a healthy Puget Sound will require a
doubling or tripling of current expenditures.” This is a critical barrier to implementation that we hope
PSP will analyze and develop proposals in scale with the magnitude of the shortfall.

As part of such an analysis, we encourage PSP to evaluate whether economic incentives and
disincentives are properly aligned with achieving progress on Puget Sound recovery. For example,
the state’s hazardous substance tax does not apply to chemicals sold for home use. Applying such a
tax could reduce their use and generate funds for Puget Sound recovery. In Saving Puget Sound,
author John Lombard notes that “….correcting current subsidies for environmental degradation
could easily pay for an ambitious regional conservation program….”.

In the blue sidebar on the right side of the page, please remove the modifier “even” in front of
dedicated. Without dedicated new sources of funding, the Action Agenda will largely go
unimplemented, see our comment on insufficient funding on the previous page of this letter.

RCW 90.71 requires that the Action Agenda “identify the agency, entity, or person responsible for
completing the necessary strategies and actions, and potential funding sources.” We assume this
p.298 Funding Strategy section: Proposed Funding Actions: Recommend adding three NTAs to this
list aimed at increasing funding for on-site sewage systems and local OSS programs:
(1) authority for counties to use property tax statements to collect rates and charges for local on-site
sewage programs (currently no NTA#);
(2) evaluate options to fund a regional low-interest loan program to repair and replace on-site
sewage systems (C5.3 NTA 1).
(3) evaluate options to establish a regional funding source for local on-site sewage programs
(currently no NTA#).
In the Funding Strategy section add:

“FS1.7 Require Continuing Mitigation for Continuing Impacts.
When the continuing impacts study called for in Appendix E is complete enough to be usable, assess
the annual dollar value of the continuing impacts caused by each land parcel, and require mitigation
either by removal of the impact or by annual payment to compensate for the assessed magnitude of
the impact. Utilize these payments to fund regional watershed protection and restoration projects
off site. Phase in the mitigation requirement sequentially, at the time each impact-type assessment
is completed. (See “Quantification of Continuing Impacts Caused by Land Use On Each Parcel” in
Appendix E.)”
• Develop viable funding strategy: We appreciate that the PSP is aware of the need for adequate
funding but are concerned that the Action Agenda includes insufficient direction on how to move
forward. More work is needed to quantify the costs for Action Agenda implementation, describe top
priorities, document funding gaps, describe funding challenges, and develop proposals to overcome
those challenges. We would like to see a document that lays out a clear framework for how funding
for Puget Sound should be considered within the context of our region’s economic recovery and
other funding needs, including funds necessary to carry out existing regulatory mandates. The
funding strategy should set appropriate expectations and set realistic timelines for what can be
achieved. It should look for opportunities to coordinate activities with other regional initiatives and
to create partnerships among government, businesses, and landowners. We are supportive of the
creation of the Ecosystem Coordination Board funding committee and want to participate in the
development an integrated, federal, state, and local funding strategy.
• The Action Agenda needs to provide quantitative information of the estimated funding need to
complete the high priority actions recommended, as well as information about current focus and
investment levels (including current and future investments to comply with existing regulatory
mandates). The financial needed in non-urbanized areas as there has beendrawing from past
Funding: More funding is strategy should identify significant funding gaps, less impact to the
marine resources. Federal, State and regional funding with transfers from urban to less populated
areas may need to be considered.
Funding

The Action Agenda outlines a suite of proposed funding actions for 2011-2013, all of which will need
to be implemented. We applaud the Partnership’s leadership role and encourage the Partnership to
secure new sources of funding and to help determine how to use existing funding strategically and
efficiently. We look forward to participating in the discussions and seeing that funding addresses the
issues identified throughout Puget Sound, including some of those identified in the Hood Canal and
Straits Action Areas.
Funding. One of the weaker sections of the document, yet one of the most important, is the draft
funding strategy. The document does not lay out a clear, comprehensive strategy. We are pleased
by the formation of the ECB funding committee and appreciate the Partnership’s support of the local
efforts of WRIA 9 and others. However, the Partnership needs to develop a comprehensive and
integrated federal, state, and local funding strategy that links to priority actions and creates a
balance of financial responsibility. Good work has been done, both by Partnership consultants early
on in the life of the Partnership, and by WRIA 9. This earlier work should be utilized, added to and
refined in order to create a meaningful funding strategy. The strategy should identify the costs for
Action Agenda implementation, identify funding gaps and develop proposals to fill the gaps. It
should also recognize existing investments at all levels of government, as well as by the private and
non-profit sectors.

FS1.1 Maintain and enhance federal funding for implementation of Action Agenda priorities
Comment: Federal funding also supports local implementers (for ex. City of Seattle has several EPA
grants). It would be good not to rule this possibility out in the future. Add Army Corps of Engineers
to the list of federal agencies in the first bullet – they are a key source of habitat funding.

FS1.3 Maintain, enhance, and focus state funding for implementation of Action Agenda priorities
Comment: Agree. In particular, critical to restore and enhance the stormwater capacity funds as well
as the MTCA funding for Remedial Action Grants (toxic site clean-up, such as the Duwamish). If grant
criteria and project selection processes are to be aligned with Action Agenda priorities, then
priorities need to first include the mandates under existing regulatory requirements.

FS1.4 Maintain and enhance local funding for implementation of Action Agenda priorities
Comment: WRIA 9 (with the support of others) has done a good job looking into this issue. From the
Develop a robust, integrated funding strategy: The Action Agenda has done a great job of
acknowledging the need for protecting funding for programs; however, the cost of proposed actions
far exceeds the available funding. Assessing the full cost of implementing the top priorities is
paramount to achieve restoration of the health of the Puget Sound.

The Caucus Group offers the following suggestions for strengthening the funding strategy:

• Highlighting these costs and challenges in the action agenda is essential to advancing near term
actions.

• Identifying gaps, clarifying the top priorities, and outlining funding challenges can all be presented
in a comprehensive document that includes a funding proposal to address the challenges. A financial
assessment of Action Agenda implementation that includes the cost of regulatory mandates should
be completed and integrated in the final document.

• Filling the gap of state and federal financial investment is critical. For the South Central Caucus
Group members, the high priority targets of stormwater retrofits and salmon recovery have been
funded primarily through local sources. As evidence, the Stormwater Sub-Committee of the ECB
concluded that local governments were funding over 90% of municipal stormwater work and
recommended a significant increase in state and federal contribution to achieve a more balanced
level to protect Puget Sound as a regional and national treasure.

• We are encouraged that the funding actions listed for 2012 involve an effort to increase financial
The “2012 Funding Action” section raises several concerns, and we find the concerns recurring
throughout the document.
In this section and Table 4, we find a major focus on passing new programs, promoting the agenda
and programs of activist organizations, and acquiring interest in real property. Among the concerns
are proposed actions and measures to:
· Promote and rely upon an advocacy organization to investigate a Department of Defense Program
· Study potential tax and fee increases at the local government level
· Lobby for new programs and money
· Increase state funding for regulatory programs
· Allow non-profits to use bonds to buy commercial forestlands
· “Rapidly acquire properties” that are currently in agricultural production
It is also good that the Funding Strategy (p. 298, #6) includes the development of a legislative
strategy to adopt a local funding mechanism and acknowledges the work in the South Central Puget
Sound WRIAs on watershed-based funding mechanisms. This effort originated in King County (WRIA
9 in particular) out of frustration with the inadequate funding for implementation of WRIA salmon
plans.

P. 298 second bullet under Ongoing Programs references PSP working with Hood Canal, Pierce
County and Thurston County on an in-lieu-fee mitigation program. King County is also working on an
in-lieu-fee mitigation program that should be referenced here.
We are pleased that WRIA 9 has been asked to participate on the Leadership Council’s Ecosystem
Coordination Board subcommittee to review local and watershed-based funding mechanisms as part
of an integrated federal, state, and local funding strategy. Through our many years of experience
investigating funding mechanisms to implement multiple-objective recovery actions, we are
committed to helping the Partnership develop an integrated federal, state, and local funding strategy
to present to the Leadership Council later this year. We believe that an integrated funding strategy
will address much of the Update’s current ambiguity for moving near-term actions from a list in the
Action Agenda onto the ground. As such, we encourage the Partnership to include potential
legislative actions “at the local level” (page 15), including that legislative action will be necessary to
create a sustainable, dedicated funding mechanism and governance structure for watersheds to fund
the priority strategies and near-term actions that each of the seven geographic action areas address
in the chapter, “How are Local Areas Working to Protect and Recover Puget Sound” (beginning on
page 301).

Finally, to help us understand how federal have read the Action working and other documents. I want
A part-time resident in Jefferson County, I dollars are currently Agenda to implement priority
someone to restore my salmon stream and take care of my beach. Because it’s private property, I’m
not eligible for grant money or assistance or anything. All I can get is a bunch of signs and be a
whistleblower against my neighbors. Something I don’t want to do. Help for private property owners
isn’t addressed anywhere in the Action Agenda, how can you keep a blind eye toward this. We need
shoreline assistance for private property owners, they need tools, money and not fines.


Thank you for the opportunity to provide comments on the Action Agenda update including the proposed Near
Term Actions. We appreciate the work that has gone into this update, and the size of the task that you have
been asked to undertake.

Cities stand ready, willing and able to be productive partners in the recovery of the Puget Sound. As you know,
we are already expending great resources and effort in that direction. From updates to our Shoreline
Management Programs, to adoption of Critical Areas Ordinances in our Growth Management Act
comprehensive plans, to hundreds of millions of dollars in investments in stormwater protections, to supporting
salmon recovery – cities play a vital role in the State’s efforts to clean up the Puget Sound.

It is no surprise that city budgets have been hard hit in recent years. We have been forced to do more with less
across all levels of city government. As we are asked to redouble our efforts in Puget Sound recovery, we will be
looking closely to see what sorts of resources are proposed to be brought to bear to help us meet that
challenge. We appreciate the elements of the Action Agenda that recognize the need for increased funding for
local governments if we are to fulfill the role that is set out for us in the Action Agenda. We are concerned by the
breadth of near term actions that anticipate active local government engagement. We are not sure that this
Action Agenda fully acknowledges how constrained our ability to take on some of these new expectations will
be given the current economic climate.

We were hoping for a more refined and prioritized list of near term actions with clear and achievable
expectations. As we understand it the prioritization process will occur after the Action Agenda is adopted.
Frankly, the sheer number and often vague nature of many of these near term actions has led many jurisdictions
to hold back comment until it becomes clearer exactly which of these proposed actions will rise to the top. The
proposed timelines for many of these near term actions seem incredibly ambitious with over thirty deadlines by
2013 in “Strategy A” alone. We strongly urge the Partnership to allow for meaningful public comment to inform
the eventual adoption of priorities.
We appreciate the opportunity to review and comment on the draft Agenda released by the Partnership in December 2011. Obviously a
tremendous amount of work was required by both the public partners, as well as Partnership staff, to complete the expansive document. While
we have concerns with the draft Agenda, we appreciate the ongoing opportunity to work with the Partnership to provide a more comprehensive
path toward achieving protection and restoration of the Puget Sound.

The following comments are structured to address the process, funding and actions included in the draft Agenda. We are requesting Partnership
respond to the questions and concerns raised during the public comment process, prior to the final adoption of the Action Agenda.

Process:
Over the past several months AWB has repeatedly raised concerns related to the Partnership’s work to establish targets which were used to
derive the near-term actions in the draft Agenda. The concerns we highlighted included, among others, that the process moved too quickly to
allow complete vetting of issues; the targets didn’t adequately consider either the practical or the economic consequences of the near-term
actions recommended to meet the targets; and, therefore, the broad stakeholder participation needed to develop practical real-world targets
was, by default, replaced by resource-agency-dominated participation.
While the intended focus of these comments is on the draft Agenda, it is important the Partnership acknowledge the contentious nature of the
adopted targets. We have previously pointed out to the Partnership our perspective that setting targets were outside of the prescriptive path set
forth by the Legislature to restore and protect the Puget Sound. Instead of focusing on targets, the Partnership should have been focused on a
scientific review of the current Puget Sound restoration and protection activities, consistent with your statutory requirements.

By insisting on the development of targets, the Partnership lost valuable time and energy. The result is a compressed comment period on a late
draft Agenda.
Furthermore, throughout target setting process mixed messages were delivered on the intent of the targets. At times targets have been discussed
as aspirational, something to strive for. At other times targets were expressed as outcomes to be achieved by 2020. Several places in the Agenda
there is language stating by 2020 the targets will be met. This is best exemplified in part one which reads, “These targets articulate the conditions
we expect to achieve by 2020. They provide more precision to the Legislature’s recovery goals for a healthy Puget Sound so we can evaluate
whether we’re on our desired trajectory.” The adoption of ambitious targets raises the question of what happens if the targets are not realized by
2020? This is truly a question of managing expectations to avoid liability for the state and local governments in the future.

Nevertheless, AWB and the Partnership, through a series of meetings and ongoing discussions have identified three measures that would address
the concerns raised by the business community:
1. A resolution by the Leadership Council stating targets are not meant to be used in a regulatory manner,
2. Inclusion of language in the Action Agenda to ensure the use of the targets are not used in a regulatory way, and
3. An agreement to recommend adoption of amendatory language to the Partnership’s governing statutes, clarifying the role and use of targets in
guiding the assessment and compliance of the Action Agenda.

To date, AWB is encouraged by the Partnership’s willingness to work on the statutory fix. We do believe, however, the additional steps described
above will be necessary before implementation of the final Agenda. These tools will help guide the implementation of the Agenda by the
Partnership, as well as other partners. We would ask the Partnership to prepare a resolution that would formally adopt these measures, issue it
for public review as soon as possible, and schedule a date for adoption of the resolution by the Leadership Council. This would help to ease the
BIAW appreciates the opportunity to submit comments on the Draft 2012 Action Agenda now out for
public review. We are grateful to provide the building industry’s perspective and thank you in
advance for your consideration.

Because we represent over 8,000 businesses engaged in every aspect of the homebuilding industry,
BIAW is concerned now more than ever with ensuring Washingtonians access affordable housing.
Additional regulations and actions affect BIAW members directly and drive up the cost of housing.

Substantial work clearly went into creating and producing this 500+ page document, including the
exhaustive list of new near-term actions (NTAs). BIAW is concerned that the 200+ proposed NTAs do
not address the broader issue and cannot be properly examined without taking into consideration
the full range of funding and current actions. In order to fully examine what, if any, new NTAs need
to be adopted a full examination of all actions needs to be adjudicated to determine what is and is
not currently working, what is and what still needs to be done. The current list of NTAs looks to be an
environmental and state regulatory agency dream list, without regard to the cost of implementing,
the cost of these actions on local government planning and the cost to business, particularly the
homebuilding industry.

The Partnership must consider the reality of declining revenues in state, county and city
governments and current private sector economic challenges. That consideration is missing in the
The City and Dike District appreciate the tremendous effort that has been undertaken to develop the draft agenda, and are
supportive of efforts to improve water quality in the Skagit River and Puget Sound. We believe the draft Action Agenda’s focus
on the areas of land development, shoreline alteration, runoff from the built environment, wastewater, and loss of floodplain
function is appropriate, and we recognize the difficulty and complexity of developing programs and actions to improve water
quality within these categories.

Both the City and the Dike District want to be partners and do our part to both help develop specific projects or actions to
improve water quality in Puget Sound, and help implement those projects or actions when consensus is reached. As you
know, the City, as a general purpose government, and the Dike District, as a special purpose district, have important
responsibilities we are obligated to carry out, many of which touch upon the areas of the Action Agenda’s focus. We have
knowledge and perspective that can provide valuable insight into developing approaches to improve water quality in the areas
the Partnership is focusing on.




Thank you for the opportunity to review the strategies and proposed actions to clean up Puget
Sound. We recognize this work is very important to the environmental and economic health of our
region. City of Bellevue staff reviews of the draft Action Agenda raised a number of questions which
we hope you will consider as you finalize this effort.

In general, the document does not recognize the role that local governments have in implementing
many of the actions. Local government should be included and participate as "secondary owner" in
any actions affecting land-use, stormwater management, or other local jurisdiction implementation
areas. This will likely require additional funding for staff support. The Partnership should seriously
consider the resource limitations of local government in these areas during the prioritization and,
hopefully, winnowing of the near term action list to a more manageable size.

In addition to the general comments, specific strategy and task comments follow (....)

We look forward to seeing revisions in this document and learning more about the prioritization
process. We hope you provide another opportunity to review and comment once the revisions and
priorities have been established. If you have questions about these comments, please feel free to
Thank you for the opportunity to provide comments on the draft update to the Puget Sound Action Agenda (Draft). The task
of creating a “science-based action agenda that leads to the recovery of Puget Sound by 2020” and achieves the goals further
set out in statute is a challenging task. We appreciate the efforts made by you and other Puget Sound Partnership
(Partnership) staff to update the current action agenda, and recognize the difficulties inherent with achieving this ambitious
goal. Unfortunately, we have significant concerns with the current version of this draft document because it lacks both
strategic focus and measurable basin-wide recovery actions. In revising the 2009 version of the Action Agenda, we sought to
1) improve the nature of the recommendations, 2) increase the certainty that these recommendations will make measurable
contributions to recovery, and 3) perhaps most importantly, bring strategic focus to the plan. To better meet these three
objectives, we offer the following feedback to, in our opinion, improve the Draft and focus the approach to Puget Sound
recovery. Clearly state the purpose of the document and state its value as a foundation for the next steps. It should be easy
for a reader to understand the purpose of the document. The Draft is a very long compilation of good contributions to, and
information about Puget Sound recovery. The nature of the recommendations in the Draft is generally more accurate or
strategic for narrowly defined topic areas such as oil spills or invasive species, and less so for broader topic areas such as
shoreline management or managing growth and development. The comments we offer in the pages that follow this cover
letter are intended to improve the accuracy and strategy for particular topic areas. The resulting, improved compilation of
recovery recommendations is a foundation on which to build a strategic approach.
The Draft must represent a science-based plan for the recovery of the Sound by 2020.
The Draft needs to explain the relationships among its parts: what are the relationships among the statutory goals, recovery
targets, pressures, strategies, and the near-term actions (NTAs)? It appears that various and relatively independent groups of
topical experts developed the content without the benefit of a uniting framework or set of guiding principles. Further, the
most specific recommendations included only NTAs that address the work over the next 18 to 24 months. There are no
specific actions, priorities, or interim goals to guide our work and evaluate progress between the 2014 and 2020. This Draft
cannot become a science-based plan without new analyses and major revisions.
We need to have a meaningful discussion to decide whether there are adequate time and resources to do the analysis
necessary to make these changes. If so, we would like to pursue the science panel’s notion of a risk assessment, which could
be done in the near term to improve our understanding of critical paths to recovery. It would have the added benefit of
improving integration of the Action Agenda and the Biennial Science Workplan.
Department staff resources are limited
The Partnership often relies on the Department’s limited staff resources because they are regional experts, managers of
critical programs, and committed to Puget Sound recovery. We must use staff resources wisely given all the other important
agency priorities they are working on. We look forward to participating in meetings and processes that include adequate
preparation time, effective agendas, thoughtful follow through, and avoid making simultaneous demands on our limited staff.
We appreciate the opportunity to provide this feedback, and will continue to work with the Partnership towards the
completion of an Action Agenda. This commitment comes with an expectation that the comments provided in this letter and
the more detailed comments that follow are viewed by you and your staff as valid and worthy of meaningful discussion. We
look forward to continuing the model of collaboration that our agencies have built as we complete the effort of adopting and
DNR thanks the staff at PSP for their effort in developing this draft. It is our hope that DNR’s comments will assist PSP in refining the draft into a
document that can truly be the lasting blueprint for recovery. PSP may wish to consider whether to take the time now to develop such a
blueprint, rather than adhering to the April adoption schedule.

Given the importance of the Action Agenda, many DNR staff contributed to the analysis included in this comment letter, including personnel in
Aquatic Resources (especially the Nearshore Habitat Team), Forest Practices, Trust Lands, Forest Resources and Conservation, Transactions,
Budget, and Executive Management. We are happy to meet with PSP staff to provide clarification on any of these comments.

It was not possible, given the length of the document, to note every potential inaccuracy or omission. Therefore, our comments are, for the most
part, at a strategic level. Examples of the kind of details that PSP might revisit include the fact that many of the strategies do not note their
importance to eelgrass recovery or other targets (for example, B.1 and the entire Reduce and Control the Sources of Pollution section); the failure
to mention DNR’s Aquatic Landscape Prioritization in key places in the document (for example B.1.1); no results chain or “target view” on forest
runoff and no linkages between forest runoff and the ecosystem conditions that we would like to address by improving runoff. We address these
and other priority concerns below but have not attempted to cover everything.

We provide general comments, which focus on the five issues PSP has asked reviewers to consider, followed by comments on near-term actions,
and lastly, other detailed comments.

General Comments

DNR respects the work done by PSP to produce the 500-plus-page document. However, to make the Action Agenda truly usable as the region’s
roadmap to recovery, the document should be simple with an easily understood critical path to 2020 that is strategic, effective, measurable,
accountable, and engages the public. It is essential that the path forward be one that the public embraces, is adequately funded, and where clear
authority exists or is obtained to get the job done. The Action Agenda should not be a so-called “playbook” where implementers can cherry pick
the actions they prefer to take – this is the way we have been approaching Puget Sound plan implementation for 25 years and this strategy hasn’t
worked. Instead, the Action Agenda should be conceived of as a blueprint with all the dependencies and inter-relationships among targets and
strategies and the actions that are necessary on the critical path to recovery. This is the only way to construct a system wherein implementers can
truly be held accountable. Since we implement within an adaptive management framework, the blueprint for the critical path can be revised over
time where results in the Sound show that management changes are necessary to achieve success.

Unfortunately, the draft Action Agenda obscures rather than illuminates a science-based strategy for achieving recovery. The information
contained in the draft will be a useful foundation for creating a truly ecosystem-based strategy (EBM) for recovering the Sound to health by 2020.
The draft as it stands is unnecessarily complex and depending on which chapter one is looking at, the focus is either geographic, ecosystem
Vital Signs p.6, Table 1 - Shellfish section, add: Research to better define collateral environmental
benefits of shellfish aquaculture for nutrient removal.

*p. 15- Potential Legislative Action, State Level, bullet 3: This item (collecting OSS rates and charges
via county property tax statements) may have been accidentally deleted from the wastewater
section. It should be listed as an NTA in Strategy C5.3.

p. 164 - The strategies to control the sources of pollution (bulleted list) could include the “Use
Outreach and Education to promote behavioral changes to reduce pollution inputs to Puget Sound.”
Similar to B1.3, page 118. This identifies DOH’s ongoing program to educate the public on shellfish
protection and onsite sewage system maintenance.

p.513 - Acronyms, Terms and Definitions: Suggest adding the following acronyms:
- OSS, On-site Sewage System
- LOSS, Large On-site Sewage System
- MRA, Marine Recovery Area
- LHJ, Local Health Jurisdiction
- WWTP, Wastewater Treatment Plant
As if to belie PSP's motto, Puget Sound Starts Here, PSP's Action Agenda is almost entirely Puget
Sound, salmon, shellfish and Orca focused yet most of Puget Sound's degradation is caused by
human activity on the lands that surround and in the watersheds that feed Puget Sound.
Furthermore PSP's message to the people causing this harmful human activity is narrowly focused on
issues that they individually can presumably control, e.g., pick up their dog's poop. What is missing is
enlisting meaningful engagement by citizens in acts of restoring the degraded groundwater, stream
reaches, wetlands and lakes that ultimately discharge into Puget Sound. Current environmental
regulations stress preservation and protection of our currently degraded streams, wetlands and lakes
and make it all but impossible for meaningful restoration to take place.

I have commented on a number of occasions (see the attached) to representatives of the Puget
Sound Partnership that their track record of enlisting the hearts, minds and efforts of citizens in
regard to meaningful engagement is terrible. PSP's focus has been on engaging governmental
agencies, tribes, scientists, academics and narrow focus environmental organizations in the pursuit
of preserving and restoring Puget Sound. So far PSP has failed to capture the attention and enlisted
the engagement of private citizens, many of whom are eager to make an environmental difference
but are alienated it is clear effective exclusion from past concerns engagement with PSP.
In reviewing the draft,by their that PSP is being responsive to meaningful expressing the need for greater transparency
and documentation to support the important and challenging body of work needed to achieve Puget Sound recovery by 2020.
As a result, PSP has presented a very expansive and detailed recovery plan. As your team has developed the draft, PSP has
reached out to Ecology in an increasingly thoughtful manner and sought to better engage technical experts in the Action
Agenda development process. The resulting product is one that is far more detailed than the previous version. In fact, the
draft has become so broad and detailed as to dilute focus from key priorities. We know PSP recognizes this, so we look
forward to working with your team over the next few months to refine the draft into a final that has more strategic focus. In
your “Letter to Reviewers,” PSP asked that we pay particular attention to five focal areas. You will find our thinking on those
questions in the attached Appendix 1. We also have provided detailed comments on the draft text of the Action Agenda in the
attached Appendix 2. We hope our comments help improve the draft. Again, Ecology would like to thank PSP leadership and
staff for the tremendous effort on the update to the Action Agenda. We look forward to working with you to produce a final
Action Agenda that puts us squarely on the path to 2020 recovery.

Strategies and sub-strategies. In general terms, the update to the Action Agenda provides considerably more logic and
rationale for advancing needed action for Puget Sound recovery that the previous version. As proposed, the strategies and
sub-strategies provide a sufficient framework to advance regional recovery, but the plan can benefit from simplification. Two
suggestions to improve the framework are:
a) Simplify the overall framework (e.g., combine sub-strategies), to help refine, focus and elevate priority actions.
b) Build into the framework an expression of benchmarks; the needed milestones that demonstrate progress toward the 2020
goals. These can be policy and/or environmental outcomes, but there is a need to understand whether we are making
progress on the recovery arc.
Proposed near-term actions. The proposed NTAs require additional refinement to accomplish the “change agenda” needed at
this point in the recovery trajectory. General comments on draft NTAs include the following:
a) We support PSP’s acknowledgment of the need to “winnow down” the number of NTAs by eliminating some and combining
others. Ecology provides several recommendations in the attached appendix to help achieve this objective.
b) It is not clear the difference between ongoing work and NTAs. Some NTAs are characterized as ongoing work. For example,
completing the PAH CAP in 2012 is a NTA, but developing rules by December 1, 2012 to implement the state law relating to
brake friction material is not. Need to understand the rationale of such decisions. We would like the opportunity to work with
PSP to help determine how to appropriately sort such actions.
These are a series of components that we have identified as core elements of Marine Spatial
Planning (MSP). There are several actions from the Action Agenda which support initial MSP efforts.
Below is a review of the overall scope of MSP within the Action Agenda.
What are the distinct components of marine spatial planning that result in benefit added results?
(Distinct components of MSP = Components of the MSP management process that are different than
current resource management)
1) A comprehensive spatial management plan for a marine area which identifies current and future
spatial and temporal distributions of human uses and marine resources (in map form)
PSP needs specific future goals to which NTA can be traced. PSP appears to be in the initial stages of
data collection as evidenced by their data collection of human uses, ID of ecological processes and
locations of habitat which support these process and ID of present and future location of shellfish
beds based on HAB conditions. In order to be a fully completed MSP, comprehensive data sets will
need to be collected and a process initiated that facilitates the decision making process for
determining the location of present and future uses.
2) Public involvement in planning process to determine tradeoffs and achieve balance among
competing social and ecological objectives. This includes identifying appropriate uses in time and
space.
PSP has taken preliminary steps to support this MSP component by engaging stakeholders in the
involvement of human use mapping and creating Local Integrating Organizations which coordinate
recovery actions. In order to be a fully functioning MSP planning process, much greater public
involvement in the planning of MPAs and other spatial zones will need to take place.
3) Large scale, cross sectoral and cross jurisdictional planning and coordinated decision making
Consistent use of these terms to describe elements of the Action Agenda would contribute to a
framework that is more easily understood and reviewed. The terms “strategies” and “sub-strategies”
appear to be used interchangeably. Future Action Agenda updates and near term implementation
may benefit from a framework in which there is greater consistency in what these terms refer to.

The Full Report should present an inventory of ongoing programs to facilitate identification of critical
gaps. The Science Plan (Appendix B for recently completed and ongoing research; Appendix D for
state monitoring programs), does tabulate ongoing programs, however, these appear to be science
related research and monitoring issues only. There may be some ongoing programs outside the
science domain which should be included.

We would like to see exploration of the idea of cooperative baseline mapping such as using the BC
Shorezone Mapping that is exactly comparable to that done for Washington and Alaska.
Thank you for the opportunity to comment on the draft Puget Sound Partnership Action Agenda and Biennial Science Work Plan for 2011-2013, dated December 9, 2011.
The Environmental Caucus has reviewed the draft Action Agenda, Work Plan, and associated documents and offer the following general comments. Specific comments
are included in Attachment 1.

 • Responsiveness summary. We continue to be frustrated that we send in comments to the Partnership and attend meetings and yet many of our suggested edits and
improvements are not incorporated in the documents. At this point, we recommend that a responsiveness summary be completed that indicates why comments
submitted by partners, stakeholders and the public are not included. To save time, the comments could be lumped into categories. Responsiveness summaries are
standard operating procedures for most state organizations.
• Monitoring and Education. We are concerned that monitoring and education are included as actions for some strategies but not all. We have commented numerous
times about this concern and yet we see this mode continued in this draft and we fear the final Action Agenda will include this uneven approach. Monitoring and
education are critical functions and are needed for all strategies! They should be listed as specific actions in each strategy or should be listed as over-arching strategies. In
addition, these are areas where many of the partners, especially including your nonprofit partners, can play a role -- again, across all of the strategies.
• Increase Compliance with Laws. The topic of compliance is only listed in one place in the Action Agenda (C1.5. Increase compliance with and enforcement of
environmental laws, regulations, and permits). We believe that this is an over-arching action that pertains to every strategy in the Action Agenda and should be so
designated.
• Relationship with Federal Agencies and Tribes. The Action Agenda can play a more vital role in improving coordination and accountability between state, federal and
tribal regulatory programs. The identification of which State Programs have delegated federal authority needs to be identified to assure there is adequate coordination
between programs such as Coastal Zone Management Program that is now playing a central role in the development on the National Ocean Policy.
• Climate Change. Climate Change is also an over-arching issue and should be included universally with all of the strategies or should be listed as an over-arching
strategy.
• Near-term Actions.
o We would like clarity of how you will incorporate the draft near-term actions that are not selected as near-term actions in the final Action Agenda. Most of the draft
near-term actions are important and we hope you do not plan to simply omit them from the document if they are not selected in the prioritization process.
o We do not have clarity of the timeline nor the scope of the prioritization process.
o We would like to have a public review period for the near-term actions that are selected as priorities.
o For each of the final near-term actions prioritized, we would like to see the funding plan for that particular action.
• Improved Executive Summary. The draft Action Agenda is too long for decision-makers to read and so we are pleased to see that a short Executive Summary has now
been included. It would be more helpful if this was a stand-alone quick read. Currently the draft Executive Summary primarily focuses on describing process. We suggest
that it be revamped so that it tells the whole story of what is needed to recover Puget Sound: What is needed, Who will do it, and How will it be accomplished as well as
What will be accomplished in the next two years.
• Salmon-centric approach. While recovery of salmon runs is a critical issue, the recovery of the entire ecosystem is important - to support both salmon as well as the
entire spectrum of species. We would like to see more information and attention focused on other species in the Action Agenda.
• Missing items. There are many items within the draft Action Agenda that are missing (e.g., “To be determined”). We request the opportunity to comment on these
missing items as these items become available for review.

The mandate to recover Puget Sound by 2020 calls for bold action. The Action Agenda is the place to include the true “change agenda” to put the Sound on the road to
recovery. Many of our comments in the attachment include recommendations for improvements to significantly strengthen the document. Thank you for your
consideration.

REGARDING PROPOSED CHANGES TO THE DEFINITION OF NTA TO INCLUDE ONGOING PROGRAMS
Many of the NTAs are dependent upon ongoing programs to move forward; however, these inter-dependencies are not clearly identified in the draft Action Agenda
Update. The prioritization of NTAs must consider ongoing priority program needs to ensure that the NTA list can be integrated into effective implementation strategies.
EPA does not think that it is appropriate to redefine ongoing program needs as Near Term Actions. While some of the same prioritization criteria used for NTAs may be
appropriate for ranking ongoing programs, the process must reflect the difference in scale (programmatic level vs. individual NTA project level) other important factors.
For example, many of these ongoing programs are required by statute, regulation or the specific mandate and mission of an agency. Prioritization processes of ongoing
and new activities to restore and protect Puget Sound should consider both ongoing programs and NTAs separately and appropriately. The results (priority lists for NTAs,
ongoing program needs, science needs, geographic needs) should then be integrated into complementary implementation strategies that are more closely directed at
specific environmental outcomes.

MANY OF THE NTAS ARE NOT CURRENTLY ACTIONABLE AS PRESENTED
In many cases, either the description, intent, outcome, approach or lead entity is not adequately described to position the proposed NTA as being ready to fund or
initiate. This problem could be relieved if under-developed NTAs were to be called out to be refined, more adequately scoped regarding intent, approach, or desired
outcome rather than attempting to launch an unclear or under-developed action (actions that do not appear to be ready for implementation as currently described are
noted in the following NTA-specific comments)

GENERAL COMMENTS
 It would be useful to provide a reference for materials or identify them in the Action Agenda so that readers unfamiliar with initiatives and its recommendations can
review them. This comment also applies across the Action Agenda, to the general need to reference documents mentioned.
The overall issue of how to get humans to collectively reduce their ecological footprints could be more explicitly acknowledged and addressed in the Puget Sound Action
Agenda. Without addressing the current patterns and trends of human consumption, occupation, and growth, it will not difficult to achieve the overall goals of the Action
Agenda. Adoption or reference to Mathis Wakernagel’s concepts might be useful. See http://footprintnetwork.org/en/index.php/GFN/
Local NTAs have been included in some places within the draft Action Agenda, but it isn’t clear if all of the local NTAs will be integrated into the main body of the
document and intermingled with the basin-wide NTAs. The Action Agenda should be clear on how local NTAs are going to be included in association with the basin-wide
NTAs in the prioritization process.

REDUCE AND CONTROL THE SOURCES OF POLLUTION TO PUGET SOUND
We suggest changing the title for this section to “Prevent, Reduce, and Control the Source of Pollution to Puget Sound”. Prevention is discussed as the main strategy yet
it is not reflected in the title.

LOCAL AREAS
The Action Agenda should establish and describe a clear, regular, predictable process by which LIOs can present the results of their local prioritization process and
recommendations/requests for funding to the Management Conference. Reading through the different LIO profiles, it becomes apparent that even as each LIO
endeavors to identify and align local priorities with Action Agenda regional priorities, there is no established mechanism by which local priority actions are presented and
reviewed for funding. A funding strategy for implementation of local recovery efforts is called out on page 303; “All areas agree that implementation of the funding
strategy is needed to support local recovery efforts, and that common outreach messages are a key to understanding in all communities.” These two clauses should be
separated. In addition, an affirmative statement should be added to the text, committing the PSP Management Conference to addressing the funding strategy
Thank-you for the opportunity to comment on the 2012 draft agenda. We are uncomfortable with
the way the process has been handled thus far. Outreach has been very limited. Issues have not
been thoroughly vetted. Near term action items are not based on science and yet are written as
regulatory statements. There are numerous near term actions that would affect our agricultural,
landscape and forestry members. We have chosen at this time to focus our comments on three we
found most concerning.

(...)

We believe that much more work, including stakeholder outreach, is necessary. We look forward to
future conversations about the health of Puget Sound and its citizens.
The Friends of the Earth (FoE) is a national non-profit environmental organization that has
maintained a presence in Seattle and the Northwest for over 30 years. FoE is part of a global network
representing more than two million activists in 76 different countries. With offices in Washington
D.C. and San Francisco, and members in all 50 states, we understand that the challenges facing our
planet call for more than half measures, so we push for the reforms that are needed, not merely the
ones that are politically easy.

FoE appreciates the opportunity to contribute to the ideas put forward in the Action Plan and
Biennial Science Workplan. We currently hold one of the NGO seats on the Puget Sound Ecosystem
Monitoring Program Steering Committee, participate in discussions of the Oil Spill Cross partnership
Workgroup, Strait of Juan de Fuca ERN and regularly attend Leadership Council Meetings. We submit
these comments to emphasize those issues raised in the letter submitted by the Environmental
Caucus, which we signed on to.

We believe the Action Agenda can play a more vital role in improving coordination and
accountability between state, federal and tribal regulatory programs. There is increasing need for
leadership and accountability in our agencies entrusted with stewardship of the Sound. We look
forward to your evaluation as to how the agencies are upholding their obligations. We view this yet-
to-be fulfilled role of the Partnership as one of the most promising. Furthermore, it would be
valuable to note which of the State programs have been delegated federal authority to assure there
is adequate coordination and accountability between programs such as the CZMP that is now playing
a central role in the development of National Ocean Policy.

Our comments on specific provisions of the draft Action Agenda and Biennial Science Workplan are
set out below:
Thank you for this opportunity to provide comments on the Action Agenda Update. We applaud the
Partnership for the effort and thought applied in developing this AA Update. Partnership staff has
been exceptional to work with and we look forward to continuing that strong relationship that has
been fostered as we advance regional efforts to protect and restore the health of the Hood Canal
Action Area.

We recognize, and we believe you do as well, that existing programs are important and should be
considered in the mix of available future funding and how they fit in the context of Puget Sound
recovery. In this Action Agenda Update, however, we welcome the attempt to “tee-up” a robust list
of near-term actions that reflects new knowledge, new ideas, and the need to go beyond our current
efforts to address critical pressures.
Restoration of Puget Sound. Preservation and conservation of what is left in a natural state. jal
From 2007 through last year’s passage of ESHB 1886 we served as Coordinators for our respective
caucus’ negotiating an agreement through the Ruckelshaus Center. As you know, our negotiations
resulted in the establishment of the Voluntary Stewardship Program that intends to assure the
viability of agriculture while protecting critical areas as defined by RCW 36.70A.030 (5).
These four Puget Sound counties adopted resolutions/ordinances to opt into VSP: Thurston, Mason,
San Juan, and Skagit.
In our review, there are some 30 Near Term Actions that are either directly or tangentially related to
the implementation of the Voluntary Stewardship Program. Thus, our request that a specific Near
Term Action be more clearly stated as follows:
“Support implementation, funding, and assistance to the Washington State Conservation
Commission and those Counties participating in the Voluntary Stewardship Program”.
I wish to submit this input to the Puget Sound Partnership - Near term Action Plan/Stategy 1/19/12 Dr. Karl Spees PSP - Puget Sound Partnership 1/1/12 The citizens are
getting weary of the Big Gov. power grab redistribution schemes of the current regime. PSP, Puget Sound Partnership is just the latest iteration in this blitz. It is fairly
stereotypical of these big gov. scams. Identify/create an artificial crisis implying a need for urgent governmental intervention. Gin up data or ‘new-science’ that
may or may not be accurate or present known data/science in ways that distorts perceptions to justify some action. Assign false blame to justify some predetermined
regulatory objective. Use the gov. supporting media to blackout the obvious arguments against such scams and flood the media with scare baiters hype, hysteria, and
hyperbole /propaganda. Then divert scarce resources from necessary government functions like public safety to fund these utopian scams. Institute regulatory controls
transferring power from the legitimate holders into the hands of big central gov. or central government agencies. Think of the grand scam of Man Made Global Warming.
Think the war on affordable energy and portrayal of CO2 as a pollutant, as opposed to an absolutely essential atmospheric gas. Think East Anglia University as a
prototype for much of this scheming monumental malfeasance. Think of the DoE (Ecology) as being the surrogate of Christine Gregoire and PSP the surrogate of the
Great job on getting this out! I was reading over the action agenda and found several references to
Port Susan Bay. The "Bay" should be removed and it should just be referred to as Port Susan. Port
Susan Bay is a small Bay owned by the Nature Conservancy which is part of the overall area referred
to as Port Susan.

I would like this email to become a part of the record of comments to the Puget Sound Partnership

This fiasco is merely another means for the government to gather even more control over private
property.

I am against this plan! I want to be placed on your email list so as to be notified when any additional
comment periods become available.

Again, I am against this debacle!!! Clean up the shorelines of Seattle, Tacoma, Everett first!! You city
folks try to push the blame for your polluted waters on the rural citizens, when you city folks are the
prime polluters of our state and nation.

Out here on the Olympic Peninsula we keep our waters and forest clean and pristine, despite your
interference.

Oh, by the way: NO WILD OLYMPICS either.
Thank you for the opportunity to comment on the Dec. 9, 2011, draft of the Action Agenda. King County continues to support
the Puget Sound Partnership (PSP) and the urgent need to protect and restore Puget Sound, a national resource upon which
the quality of life and prosperity of our region depend. With responsibilities for land use, transportation, stormwater, and
wastewater, King County is keenly interested in connecting with and being informed by the recovery actions and strategies
being proposed at a Puget Sound scale.
On the whole, we are impressed by the amount of detailed information contained in the document, and appreciate the hard
work that has gone into its production. It builds on the 2008 Action Agenda, and appears to reflect legislative mandates as
well as comments by the Joint Legislative Audit and Review Committee Report--such as the need to establish targets and link
actions to them. It is obviously challenging to take on a task as complex and all-encompassing as Puget Sound recovery, and
the PSP staff team should be commended for the effort they have taken to ensure a collaborative and thorough process.
Nevertheless, we have some concerns with the draft Action Agenda Update and have suggestions for further revisions that
would help to chart a clearer path to successful implementation, summarized below. You will find enclosed as ‘Attachment 1’
more detailed staff comments organized by the five categories requested in the “Letter to Reviewers” as well as comments on
the funding strategy and the science plan.
• Focus on critical near-term actions and path forward. While comprehensive, we believe that the document does not clearly
convey the key actions that are critical to put Puget Sound on a path toward recovery. The document’s length, structure, and
terminology make it difficult to use as a call to action or guide to next steps for state agencies, Tribes, local governments,
NGOs and residents. We understand that the structure of the document was influenced by the need to be responsive to
legislative direction, consistent with the format of the previous Action Agenda, and attentive to numerous stakeholder
concerns. However, we think it is essential that the Action Agenda include a short list of easily understandable, but significant,
actions that are clearly necessary to restore Puget Sound. The concept of “strategic initiatives” introduced in this update may
be a start; but they should be linked to recovery targets, include a description of implementation challenges (including
funding), and recommend next steps for overcoming those challenges.
• The NTAs should focus on the most critical actions, and highlight the funding needed for implementation: The overall
number and varying specificity of NTAs does not clearly establish a “change agenda:” many of the NTAs appear to remain in
the Action Agenda because they suffer from lack of implementation. Many are unfunded, so the likelihood of their
implementation over the next two years is unlikely, despite the inclusion of responsible parties and performance measures. A
With over 270 miles of shoreline, Kitsap County recognizes the importance of a healthy Puget Sound.
Our County has worked with various stakeholders in developing systems to prevent further
deterioration through such innovations as Low Impact Development and the restoration of Chico and
Carpenter Creeks. Our professional staff participated in the technical and policy level discussions
that led to the development of Puget Sound Ecosystem targets and pressure reduction strategies.
Thus, we, like others, have a vested interest in ensuring the Agenda Action and associated Near Term
Actions for 2012-2013 are results-oriented and achievable. We appreciate providing some additional
insights the Puget Sound Leadership Council should consider:

The Draft Action Agenda lacks a focus that individuals, stakeholders, and governments can
appreciate. For example, one of our staff members made a telling comment while reviewing the
document when he called it a “big-picture” document that obscures how it links up with any of the
actions this County is implementing. Key to success is obtaining ownership. With a document this
massive and with so many near-term actions, how does one focus limited resources to achieve
objectives that are measurable and recognized by citizens as true results? Recommendation: Create
a limited document that is focused, results-oriented, and user friendly. For example, the 2004
Executive Summary

Page 1

This section needs to clearly define what is mean by “Puget Sound”. Most people quite logically
conclude it is inland salt water body defined as Puget Sound, and most people mentally include the
Strait of Juan de Fuca, the portion of the Strait of Georgia in Washington State, and the waters
around the San Juan Islands. However, the partnership, and perhaps the enabling legislation, has
stretched the definition to include all the drainage basin, so it now includes forests, farms, homes,
businesses, roads, lakes and rivers.

What is meant by “Puget Sound” is not clear.
We appreciate the opportunity to comment on the draft Puget Sound Action Agenda update. It is a
very long and complicated document. We will limit our comments and concerns to the document
and process as a whole rather than specifics on each strategy or action. We have participated in
many of the groups working to ensure that the Action Agenda update identified cost-effective,
transparent, and accountable actions that will reverse the degradation of the Puget Sound
ecosystem from the white-tops of the mountains to the white-caps of the open ocean. The oral
tradition and history of the Lummi community and their Schelangen knows that all actions are
interconnected and that human activities must be conducted with the understanding that
consequences might lead to the destruction of ecosystem goods and services that sustain our
Schelangen. The Lummi Schelangen depends on a healthy Puget Sound ecosystem. We need look no
further than the increase in the population in the Puget Sound region and the decline of salmon
runs.

Although legislative changes are not incorporated in the Action Agenda, there is a potential for
confusion between references to the Puget Sound Partnership as a state agency responsible to the
governor, and as a Partnership of local governments, state agencies, federal agencies, tribal
governments, economic interests, and environmental interests seeking to transparently identify and
The Chairman of the Makah Tribal Council, Micah McCarty, has authorized submittal of these
comments and appreciates the opportunity to contribute to the Action Plan and Biennial Science
Workplan. In addition to our work with the federal-tribal caucus, we have concentrated representing
our Treaty interests a members of the Strait of Juan de Fuca Environmental Restoration Network and
on the Oil pill Cross partnership Workgroup. We also have regular representation at Leadcership
Council meetings. We believe the Action Agenda can play a vital role in improving coordination and
accountability between state federal and tribal regulatory programs. It would be good for this to be a
stated goal in the Executive Summary and body of the Plan. There is increasing need for leadership
and accountability in our agencies entrusted with stewardship of the Sound. We look forward to
your evaluation as to how the agencies are upholding their obligation. We view this yet-to-be
fulfilled role of the Partnership as one of the most promising. Furthermore, it would be valuable to
note which of the State Programs have delegated federal authority to assure there is adequate
coordination and accountability between programs such as ZMP that is now playing a central role in
the development of National Ocean Policy.

On behalf of the 3,000 member is need to of the Master Builders Association research and
Overarching all these commentscompanies continue to invest in the long term of King and Snohomish
Counties (“MBA”), I am writing to submit comments on the Draft Action Agenda Update now out for
public review. Thank you for this opportunity to provide our
input.
While I appreciate all the time and effort that has gone into producing this draft and identifying an
exhaustive list of new near-term actions (“NTAs”) aimed at protecting and restoring Puget Sound, the
MBA shares many of the broader concerns raised about the draft by the Association of Washington
Business (“AWB”). Namely, we are concerned that the draft update does not adequately address the
full range of actions already being undertaken, and funds already being spent, on Puget Sound. We
believe it would be far more appropriate to review ongoing programs on the front end of the
process, not after. In its current form, the NTA list appears to be an environmental community and
state regulatory agency “we won the lottery” wish list, without regard to necessary funding,
consequence to local government planning and implementation or to our local economy.
Given the economic reality of declining revenues at all levels of government and ongoing economic
challenges in the private sector, it is unclear to me how the Partnership intends to pay for this
cornucopia of new actions. Even if the Partnership were able to identify new funding sources, it is
still unrealistic to expect we can successfully implement so many new activities in several decades,
much less two years. As the Government Accountability Office emphasized in its 2006 report on
In addition to our specific suggestions related to housing and buildable land supply (see comments
above), we believe more work is needed in two key areas:
1) Regulatory Reform – For as long as I have been involved in the Puget Sound Partnership, the
business community has raised the need to streamline laws and regulations, especially those related
to the environmental review process. The Partnership needs to address the issue of review processes
that are long, cumbersome and costly, and ultimately are counter-productive to our goals for
protecting and restoring Puget Sound. While several of the NTAs touch on regulatory reform, none of
them does so in any kind of comprehensive or meaningful way. We would urge the Partnership to
commit to working with key stakeholders to find and promote specific solutions to this issue.
2) Economic Impacts – We would like to strongly encourage the Partnership to continue its ongoing
dialogue with the business community on finding ways to ensure a healthy Puget Sound goes hand-in-
hand with a strong economy. For example, it is absolutely critical that we find an adequate target (or
set of targets) measuring the health of our economy, just as the Partnership has done with the
ecosystem recovery targets.
Thank you for the opportunity to review and comment on the Action Agenda. We appreciated the
extension of the review period, as several reviewers were required to coordinate a response.

First, we appreciate the hard work staff has put in on the multiple topics. We also appreciate the
focus on Near-term Actions. Much progress was made in making this a more workable document.
Quoting from the Whidbey Basin Science Symposium Next Steps: DO SOMETHING – despite
uncertainty,…get them done.

Second, we are supportive of the WRIA 8 submitted comments. We couldn’t have said it better.

Third, I was disappointed that typically the San Juan Islands, Hood Canal and Whidbey Island are
generally the local areas mentioned. We have been taking actions that date back to 2006. They
projects along our shoreline are working – we have reduced the uncertainty.

- Research Vs Action: The document only calls out research and monitoring and indicates
prioritization of actions is a future task. This just delays action. Start with the previous work that the
WIRAs have listed as priorities and recognize what has been done. Then using the analysis of high
benefit, adjust the priorities to make sure the greatest gain is achieved no matter the location. This
will not keep our proactive local governments from making further contributions as we still
appreciate their small runs.
Thank you for the incredible effort to developing a scientifically credible and stakeholder-driven plan to recover Puget Sound. We appreciate the opportunity to
comment on the draft Action Agenda and submit the following on behalf of The Nature Conservancy.

The draft Action Agenda includes many solid targets, strategies and actions. It clearly represents an advance from the first and includes many important actions. It
should establish a foundation for future updates. As in the past, our challenge has been to best comprehensively the breadth of what’s needed to recover the Sound,
while ensuring that stakeholders, partners and the public can clearly see the highest, most critical priority actions. We recognize the Partnership continues to work on a
high level synthesis that should provide this distillation, but nonetheless focus our comments on the need to better synthesize, integrate and communicate the most
strategic, cross-cutting actions that will break from the status quo and put Puget Sound on a trajectory to recovery. We offer the following comments and suggestions in
an effort to help the Partnership create an Action Agenda that is easier to manage and track, more broadly readable, and more clear about what must change from our
current path.

Our concerns with the draft are:

1. The document is too long. While full of tremendous information and ideas, we are disinclined to believe that many – even those entrenched in resource issues in Puget
Sound – will read and absorb the entire change agenda. Unless the document is reduced to a manageable size, we fear its power will be lost before implementation even
begins.

2. The different strategy sections appear cobbled together rather than an integrated suite of strategic actions. This “siloed” nature is a result of an understandably siloed
process that led to the development of the Update. We fully understand the pragmatic need to separate the working groups that developed the strategies. As you move
to a final draft however, the focus now should be on drawing the connections between the sections, making sure that each strategy is advancing multiple targets (and
not undermining any), and prioritizing those that advance multiple targets (by recovering the core ecological processes the Ecosystem depends on). To move beyond the
status quo and accelerate recovery we need to find efficiencies between the many aspects of recovery.

3. It appears to be all-inclusive – as if the effort was to collect every possible strategy and action rather than to try to identify the most critical elements of recovery.
Before we even get to prioritization we believe some strategic choices about what is most important need to be made. We need to move beyond the status quo. To
create the change that is needed, we need to make sure there is an awareness of those things that are most important and ensure agency resources and efforts are
channeled in that direction. The AA should serve as the starting place for that change.

4. The Agenda seems to downplay the role of estuary restoration (particularly dike removal) in Puget Sound recovery. There are no strategies directly related to estuaries,
in contrast to other system components like floodplains, beaches and bluffs. Though the topic of armoring could conceivably include dikes, the strategy description is
clearly targeted at bluffs and beaches, and there are no estuary-related NTAs. Few, if any, NTA’s clearly target estuaries and the draft AA appears to place all estuary
restoration hopes and responsibilities on the Chinook recovery efforts. As estuaries are at once the most productive and most degraded habitat type in Puget Sound,
this would seem to be shortsighted.

In lights of these concerns, we offer the following recommendations:

1. Create a short, polished final draft. Pull out the suite of those strategies deemed most important through the integration and culling process described below and the
planned prioritization process. Move the existing strategy sections to an appendix and eliminate the local scale actions that are included inconsistently and appear out of
As the ECB representative from the North Central Action Area, I wanted to submit a few general
comments that have come to me on the Action Agenda

The document is so substantial and has so many actions that there is concern that it is simply too
complex to understand, implement or monitor. The concept of focusing on strategic initiatives is
supported. There should be less Near Term Actions, we need to choose the most important priorities
to focus on.

Local governments have huge concern about another layer of bureaucracy, especially one that might
not be in sync with other regulatory agencies. Local jurisdictions are struggling with declining
resources, staff layoffs, compliance with GMA, new NPDES and storm water manual requirements,
SMPs and numerous other regulations. Local electeds are concerned about the economic struggles in
their communities, retaining jobs and being able to provide adequate services. In our area, most of
our jurisdictions are also involved with TMDLs. Comments on the proposed new Storm water
manual, NPDES permit, the Liberty Bay TMDL and Puget Sound Action Area are all due
simultaneously. It is overload.

It is essential to address the differences between urban and rural areas. Urban areas are required to
accept density under GMA, expectations for urban areas have to be compatible with the goals of
increasing urban density and decreasing sprawl into rural areas.
Thank you for the opportunity to comment on the draft Action Agenda Update. The update is a
major undertaking and we recognize efforts the Puget Sound Partnership (Partnership) has made to
ensure this endeavor is comprehensive and includes input from diverse interests across the region.
Our comments include contributions from staff in several divisions of the NOAA Fisheries’ Northwest
Regional Office with expertise in habitat management, marine mammals, mitigation and salmon
recovery. We focused our comments on portions of the update we believe are most pertinent to
salmon, steelhead, marine mammals and the habitat upon which they depend.

The Action Agenda provides a useful organizational framework of strategies, conceptual models and
targets. It could be strengthened during the update process by adding specificity to the near term
actions (NTAs) and clarifying responsible parties. Several of the NTAs describe important action
steps, but do not explain what entity is responsible for taking the action.
It is our understanding that the “strategic initiatives” which establish the Partnership’s priorities for
the next biennium are still under development. We recommend the Partnership include
implementation of existing recovery plans as a strategic initiative. NOAA approved recovery plans for
Puget Sound Chinook and Hood Canal Summer Chum salmon and Southern Resident Killer whales.
Those plans are scientifically sound and include specific actions that directly relate to recovery of the
Puget Sound ecosystem.
On behalf of the Northwest Pulp & Paper Association (NWPPA), thank you for the opportunity to
provide comments and feedback on the Partnership’s draft Action Agenda
update.
The NWPPA is a 56-year old regional trade association representing members companies in
Washington, Oregon and Idaho. NWPPA represents eight (8) member pulp and paper mills in
Washington State. Our Washington members currently employ approximately 4,000 people. The
average pulp and paper mill worker compensation is over $65,000 annually, plus benefits. These are
predominately union-represented jobs that provide family-wage employment. Many of these jobs
are located in rural communities, faced with the highest unemployment rates in the state. These high-
wage manufacturing jobs support a 3-to-1 job multiplier, and even higher in rural communities. Until
recently, Washington had shrunk to only 12 pulp and paper mills operating in the state. That number
now stands at 11 with the recent announcement by Kimberly Clark that it will close its facility in
Everett, costing approximately 750 family-wage jobs.
As you know, NWPPA and the business community, generally, have been supportive of Governor
Gregoire’s and the Partnership’s goals of a clean and healthy Puget Sound by 2020. A clean and
healthy Sound, along with a vibrant economy, make the Puget Sound and the State of Washington
an attractive region in which to live and provides the high quality of life and beautiful environment
we’re all accustomed to.
We have reviewed the comments of today’s date from the Association of Washington Business
(AWB) and endorse the points raised therein.

(...)
Our comments are focused on:
1. Acknowledging the role that we play regionally to coordinate and support MRCs, implement
regional restoration projects and expand regional stewardship through local MRCs.
2. Improving recognition for the work already carried out by the Northwest Straits Initiative in “on-
going programs”
3. Identifying new appropriate Near Term Actions where we see a good nexus with our
organizational capacity and expertise

Locally Developed Information in the Action Agenda: p. 20
As written, this section does not acknowledge contributions from local entities such as the
Northwest Straits Initiative provided prior to and during the formation of LIOs.
On behalf of the Northwest Indian Fisheries Commission (NWIFC), we would like to provide the
following comments and recommendations on the update of the Puget Sound Action Agenda. To
preface the following comments from the NWIFC, we wish to clearly state that this letter is an effort
to communicate commonly held concerns. It does not, however, replace or supersede any comment
or communications from individual member tribal governments to the Puget Sound Partnership
(PSP).

The NWIFC is composed of representatives of the twenty federally recognized treaty tribes of
western Washington. These tribes possess rights reserved by treaty to manage and harvest various
natural resources, including fish and shellfish. These rights have been exercised since time
immemorial and their protection must be considered when creating a plan to achieve a healthy
Puget Sound. Currently, these rights are at risk because salmon habitat is being destroyed faster than
it can be restored.

Statutory goals for Puget Sound recovery include a healthy human population supported by a
healthy Puget Sound and a quality of life that is supported by a functioning ecosystem. These goals
have tremendous meaning to the tribes of the region. Their quality of life and economic livelihood
depend on a healthy Puget Sound ecosystem.

Updating the Action Agenda is an important task to help protect our treaty reserved-resources and
represents substantial effort from the PSP and its staff. Nonetheless, we do not feel that the Action
Agenda adequately reflects the measures necessary to protect salmon and shellfish. Therefore, we
would like to impress upon you the importance of protecting our treaty rights by ensuring that the
Action Agenda supports habitat protections consistent with salmon recovery by better protecting
salmon habitat, including water quality. To accomplish this we provide the following:
1. The Action Agenda must serve as a living document able to incorporate state and federal
responses to the Treaty Rights at Risk (TRAR) initiative.
2. The Action Agenda must also serve as an instrument to align state and federal programs to be
consistent with protecting treaty rights, salmon recovery and state water quality standards.
December 2011 brought the Governor's public announcement of the Washington Shellfish Initiative (WSI), arguably the most
significant boost to the shellfish industry and shellfish resources in the state since the passage of the Bush and Callow Acts in
1890's. The Initiative confirms the State's commitment to an industry and resource that has fueled local rural economies for
decades. Combined with the work that Puget Sound Partnership has done to lead the state to a "swimmable, diggable,
fishable" Puget Sound, shellfish growers are more confident that the industry can support future generations of farmers. On
behalf of the Pacific Coast Shellfish Growers Association (pCSGA), I am pleased to provide these comments on the December,
2011 draft of the Action Agenda. The convergence of the WSI and the Action Agenda present an opportunity for each effort to
succeed. We applaud the State's efforts to both restore the health of our marine ecosystems and economy by advancing an
aggressive Action Agenda and the WSI.
The Pacific Coast Shellfish Growers Association (PCSGA), founded in 1930, represents shellfish growers from Alaska,
Washington, Oregon, Hawaii and California who sustainably produce oysters, clams, mussels, scallops and geoduck. These
dedicated individuals pride themselves not only on the quality and freshness of their shellfish but also in their role as
environmental stewards, mindful of the dynamic conditions in the marine environment. PCSGA represents both private and
tribal shell fishing interests and most members farm because their parents, grandparents and even great-grandparents did -
demonstrating a longstanding commitment to the State's natural resources.
We recognize and appreciate the tremendous effort that was put forth to assemble this document and establish links between
actions and recovery targets. The Draft Action Agenda (December, 2011) represents hours of meetings with stakeholders and
consideration for how to restore Puget Sound. The Washington members ofPCSGA are pleased to be part of this process and
on behalf of those members, I respectfully submit these comments. These comments are structured to provide general
comments on the document followed by specific comments on the recovery targets and Near Term Actions. The specific
comments are primarily focused on Target C.9- Abundant, healthy shellfish for ecosystem health and for commercial,
subsistence, and recreational harvest consistent with ecosystem protection.
We understand that there are several things that remain to be done in order to complete the Action Agenda, such as more
comprehensively addressing climate adaption needs, identifing, refining and prioritizing local strategies and actions, assigning
appropriate performance metrics and adequately assessing the efficacy and priority of ongoing programs before assigning
priority to Near Term Actions. We see the value in this work and would like the opportunity to participate and provide input as
that work progresses.
In particular, please involve the shellfish community in your discussions on climate change as the industry has already, and
unfortunately, begun to experience first-hand how changes in the ocean due to climatic changes can effect marine species.
The shellfish community has rallied together real-time water quality data and are exploring ways to adapt to the changing
Thank you for the opportunity to review and provide comment related to the December 9, 2011
Draft Action Agenda. The Washington State Parks and Recreation Commission (State Parks) has long
been a partner in Puget Sound recovery efforts and looks forward to continued participation. Please
note that this review is in specific regard to the Near Term Actions (NTAs) for which State Parks
would be responsible. State Parks looks forward to the upcoming February 10, 2012 meeting with
Puget Sound staff to further address the items below.

Given the current desire to reduce the amount of NTAs, State Parks will not be proposing any new
NTAs. However, it appears from the available draft documents that actions that State Parks has the
capacity to track for performance measurement are largely included within the existing NTA
framework and could be addressed through existing NTAs.
Has anybody in charge and accountable for money spent actually looked at this thing?

I spent time looking through several of the sections including the Summary. I was looking forward to
seeing a nice roadmap of ways to improve the state of the sound. I mean, an action agenda is a list
of what we are going to do, right? I also expected some problems and issues and some parts
showing how we are geared up to work on them. And finally some tid-bits to use in education and
outreach, which is most of what I am able to do. All backed up with useful details.

I hoped to then be able to provide some comments that would be useful, and some of appreciation.

My first reaction was mass confusion – I read several paragraphs of the Exec. Summary and got no
notion of what the whole thing was trying to do, it was so long-winded. Then I realized that it was
40+ pages, and I breezed through a few of them, and gave up.

Executive summaries can be many things. 40 + pages is not one of them.

I also realized that I do not know who the audience is for this whole set of Action Agenda materials,
but it is not me. It is full of gibberish, odd charts and diagrams, and long tables packed full of detail.
There were not summary or simple tables or charts that got to the essence of anything – a section
was called “How Do We Recover Puget Sound to Health” but all I found I could even begin to
recognize as some action was a page about potential legislative action.

I seriously doubt that anyone not being paid by the hour is going to do much reviewing of this
document. I ran a couple paragraphs through a reading-ease calculator. One was foggy but
readable, the other was grade level 16. I never found anything I could call “real simple.”
Money is in real short supply I hope the PSP work will result in actual results and not just reports and
symposiums. We do not need to add to the work load of hard working local governments.
Strategic Initiatives
The Action Agenda includes examples of “strategic initiatives”, all of which are described as
“protection.” We encourage the Partnership to clarify that their initiatives include protection,
restoration and preservation actions to avoid any impression that the Partnership is advocating only
protection through regulation as a means to achieve recovery of Puget Sound. It is impossible to
accomplish this goal without an aggressively funded and balanced approach of regulation,
restoration, and preservation.

We also suggest that the Action Agenda add implementation of the Puget Sound Chinook Recovery
Plan to the list of strategic initiatives. That Plan achieves a good balance by focusing on all areas of
salmonid decline through hatchery, harvest, habitat and hydropower integration. We further
support explicitly incorporating salmon recovery lead entities’ three-year plans and strategies as
Near-term actions.

Similarly for reasons described below, we also suggest that the Action Agenda add securing
additional, significant state and federal funding for local governments to implement municipal
stormwater management to the list of strategic initiatives. We further support sequencing of the
additional municipal stormwater requirements described in Near-term Actions to come after that
funding is secured.

Action Areas
Pierce County is one of only two counties that are included in three Action Areas: South Central,
North Central, and South Puget Sound. Pierce County notes and supports the Action Agenda’s
recognition of the importance of local implementation and that Action Areas have unique ecological
conditions and priorities that differ from taking a Sound-wide focus. We also note that currently,
only 15 of 173 Near-term Actions are designated as local actions. We recommend that the
On behalf of the Point No Point Treaty Council (PNPTC) and our member tribes (the Jamestown
S’Klallam Tribe and Port Gamble S’Klallam Tribe), we would like to provide the following comments
the draft 2012 Puget Sound Action Agenda. To preface the following comments from the PNPTC, we
wish to clearly state that this letter is an effort to communicate commonly held concerns. This letter
does not, however, replace or supersede any comment or communications from the Jamestown
S’Klallam Tribe and Port Gamble S’Klallam Tribe or from other Tribes in the Hood Canal and Strait of
Juan de Fuca Action Areas.

We will focus our comments on the Hood Canal and Straits Action Areas. In general, we are pleased
that information on the work done in the Hood Canal and Straits Action Areas is well-represented in
the Action Agenda.

(...)

Consistency and Alignment with the Treaty Rights at Risk Initiative
The Partnership is engaging with the Puget Sound Tribes to address the issues identified in the Treaty
Rights at Risk Initiative. The Federal agencies are working to finalize their response strategy to the
Treaty Rights at Risk Initiative by spring 2012. This is an ongoing effort and is a bit out-of-synch with
the development of the Action Agenda. It will be important to include in the 2012 Action Agenda the
actions identified in the Federal responses to the Initiative (and the subsequent actions required of
the State agencies and county entities). This will likely require an adjustment to the schedule of the
Action Agenda, but effectively addressing barriers to salmon habitat recovery such as shoreline
modifications, floodplain management, riparian management, stream flow, land use development,
etc., is necessary for Puget Sound recovery. We look forward to continuing to work with the
Partnership.
Thank you for the opportunity to comment on the 2012 Puget Sound Action Agenda. The comments included in
this letter reflect the opinion of the twelve Puget Sound Conservation Districts that are part of the Puget Sound
Conservation Districts Caucus (PSCD Caucus). Individually and as a group we have identified significant overlap
between the 2012 Puget Sound Action Agenda strategies and the historical activities and services of
conservation districts and the Washington State conservation district statutory mandate.

Conservation district statute, Chapter 89.08.220 RCW, provides a broad suite of corporate powers to address
local natural resource concerns. These powers include but are not limited to conducting research, educational
activities and natural resource improvement projects; working with landowners and residents to improve
conservation of natural resources; and preparing and updating a long-range plan for the conservation of all
renewable natural resources within the boundaries of individual conservation districts. Our corporate powers
uniquely position Puget Sound conservation districts to directly and positively impact the health of Puget Sound,
as well as to partner with the Puget Sound Partnership on Action Agenda strategies and priorities. With the
simple commitment on the part of the Partnership to recognize, utilize, and invest in the Puget Sound
Conservation District network, we can more efficiently and effectively accomplish the goals set forth in the
Puget Sound Action Agenda together.

Washington State conservation districts have a track record of over 70 years of conserving natural resources on
the private land base in Washington. At the heart of the success of the conservation district system in the Puget
Sound region as well as state-wide, is our established model of voluntary stewardship. This model is predicated
on our commitment to a three-fold approach, which includes education, technical assistance, and financial
incentives. And the approach – our stewardship services delivery system – is proven successful, is staffed with a
robust network of professionally trained service providers, and is the essential ingredient in cultivating durable
Areas of Strength. Puget Sound Regional Council staff commends the Partnership for pulling
together a thorough document that illustrates the variety of federal, state, regional, county, local,
public and private actions necessary to restoring Puget Sound. The draft contains a number of
strong elements, including the following:
• The indicators and recovery targets are helpful in providing definition to the broader goal
statements.
• The Guiding Principles on page 19 provide a useful framework for developing priorities.
• The Strategic Initiatives listed on page 22 will be important for maintaining public and legislative
support and momentum. This includes prioritization of on-going programs, as described on the
bottom of page 22.
Potential Improvements to the Document. The size, tone, and technical nature of the document
presented challenges in our review. There were many technical terms and acronyms and not all are
found in the technical appendices (for example the document's initial three acronyms on page 3), the
figures either have incomplete or no titles (for example, the table on page 6 and diagram on page
24), and some items are not very legible (for example, the logic model/result chain diagrams).
Thank you for the opportunity to comment on the Action Agenda. We have coordinated our
comments with the Puget Sound Partnership’s Environmental Caucus and we fully support those
comments.

In addition, we ask that you consider the role of Citizen Enforcement of the Clean Water Act in
protecting water quality within the Puget Sound Basin. Since 1992, Puget Soundkeeper Alliance has
brought over 160 citizen enforcement actions under the Clean Water Act and has never lost a case.
As a result of these actions, numerous sewage treatment plants, CSO systems, shipyards, boatyards,
construction sites and industrial stormwater dischargers have improved management practices,
structural stormwater controls and have installed or updated stormwater treatment and wastewater
treatment systems. Further, Soundkeeper has secured $3.1 million for environmental mitigation
projects to compensate for environmental damage in the affected watersheds.

We notice that several non-profit organizations are called out for their good work at various parts in
the Draft Agenda, such as on page 173, Section C1.4. If appropriate, you may want to list the critical
work of Puget Soundkeeper Alliance in achieving compliance with NPDES Stormwater and
wastewater permits in one or more of the following sections:
C2.4 Control Sources of Pollutants;
C6.2 Reduce pollution loading to Puget Sound by preventing and reducing Combined Sewer
Overflows;
C6.5 Ensure all centralized wastewater treatment plants meet discharge permit limits through
compliance monitoring, technical assistance, and enforcement where needed.
I appreciate the opportunity to review the draft Puget Sound Action Agenda and to provide
comments for improvement. As you know, the Recreation and Conservation Office (RCO) is a
dedicated supporter of your mission to restore the health of Puget Sound by 2020. Since 2007 we
have worked closely with Partnership staff to ensure RCO is administering our programs in a way
that aligns with Puget Sound recovery. We stand ready to continue working together to ensure the
greatest benefit to Puget Sound.

The draft Action Agenda is an important effort toward achieving recovery by 2020. It will be a
significant improvement over the 2008 Action Agenda as it provides clear links between your
statutory goals and your ecosystem targets and indicators. I applaud your efforts and offer some
suggestions for improvement.

Overall, I recommend shortening and simplifying the Action Agenda so that it more clearly
communicates the linkage between strategies and targets. A shorter and simplified version will allow
greater accessibility to a broader audience.

In addition, I am concerned that the Action Agenda needs to have more realistic expectations about
The City of Renton supports the protection and restoration of Puget Sound, and we appreciate the
opportunity to comment on the Puget Sound Partnership’s Puget Sound Action Agenda and Biennial
Science Workplan (PSAA & BSW).

The PSAA & BSW document is ambitious, especially with regard to the 2012 Prioritized List of Near
Term Actions. There are a number of strategies proposed by the partnership; however, the
document doesn’t explain how these strategies will interface with other regulations such as locally
adopted Shoreline Master Program (SMP) and the proposed National Permit Discharge Elimination
System (NPDES) regulations. Much of what is proposed will be overseen by Washington Department
of Natural Resources (DNR) while NPDES and SMP are managed by Department of Ecology (DOE).
Therefore, it is not clear if a strategy/requirement from one document takes precedence over
another.

The NTAs do not address the substantial regulatory changes that local governments have
implemented in response the NPDES Municipal Stormwater Permit requirements, SMP updates and
Critical Area Ordinance (CAO) updates. This gives the appearance that the NTAs assume these
actions are not adequate. Yet, there has not been analysis to demonstrate that more regulations are
Thank you for accepting these comments on the Puget Sound Partnership Action Agenda for 2012. We
appreciate how much hard work was put into this document and the coordination of so many stakeholders and
interested parties.
The aim of the North Sound Baykeeper Team is protect and preserve habitat and water quality in the Whatcom
and Skagit County region. RE Sources has approximately 800 members. On their behalf, we submit these
comments on the Puget Sound Partnership Action Agenda.
The following is a general summary of our primary concerns with the Action Agenda. More specific comments
are included within this document.
 • Climate Change needs to be addressed more completely within each action area of the agenda. There are
several strategies that fail to address how projected effects of climate change will impact necessary
management decisions.
 • Monitoring, research, and subsequent education should be major components of each strategy and action
area. Many strategies should require research into specific topics in addition to long-term baseline and
fundamental science monitoring, in order to evaluate effects of management or lack of management over time.
• Increase enforcement and compliance with existing regulations. Many of the strategies within this Action
Agenda rely on the integrity and application of existing permitting and regulatory programs. However, we are
concerned about the ability of regulatory agencies to enforce existing regulations without receiving adequate
funding and without a mandated emphasis on inspection and enforcement.
•Increase transparency within the Action Agenda and LIO process in order to allow greater pubic education and
involvement. For example, within the Whatcom County community, there is little public awareness about the
LIO process and the proposed priority actions for the region. This has resulted, in some cases, in public
frustration. Many in Whatcom County desire greater transparency of the process, including regular local
meetings which are open to the public, and which take public concern into account.
 • Incorporate equal focus on nearshore and marine recovery efforts as salmon recovery. The current Action
Agenda for Puget Sound and the local agendas for Whatcom and Skagit Counties have much greater emphasis
on salmon than any other aspect of ecosystem recovery. Greater emphasis needs to be given to nearshore and
marine ecosystems, as well as the connection between upland and shoreline land management decisions and
implications for nearshore ecosystems.
 • Greater prioritization of near-term actions for Puget Sound wide and local strategies needs to be developed.
In some sections with many near-term actions identified, prioritization within each section may be needed to
RECOGNITION FOR THE WORK OF CONSERVATION DISTRICTS
First, I would like to reinforce with you the work of the 12 Puget Sound conservation districts and the
important role they play in working with farmers in the region to address impact to natural
resources. Conservation districts are known for their decades of experience in completing successful
on-the-ground projects to improve water quality, enhance efficient water use, manage livestock, and
improve air quality. And these projects are done with the close cooperation of the landowner
ensuring the long-term success of the implemented practices.

In 2009, the conservation districts produced the Puget Sound District Caucus Action Agenda. This
document links the annual and long range plans of the 12 Puget Sound conservation districts with
the threats identified at the local Action Areas. These local threats are compiled in the PS
Partnership’s current 2020 Action Agenda. By making the connection between the work of the
conservation districts, the threats identified in the Action Agenda, and the actions identified in the
Action Agenda, policy makers at all levels of government will know that when they provide funding
for a conservation district project, they are also supporting the objectives of the 2020 Action Agenda.

The Puget Sound conservation districts are leaders in working with landowners to accomplish on-the-
ground projects with natural resource improvement results. Since 2009, these conservation districts
have provided technical assistance to 6951 landowners and developed 798 new landowner plans.
Conservation districts are trusted sources of information for landowners throughout the Puget
Sound basin.

As the Puget Sound Partnership proceeds with establishing Local Integrating Organizations (LIOs) the
PSP should ensure conservation districts are included as active participants. Experience to date
suggests this is not always the case. If we are to be successful in addressing natural resource impacts
Thank you for the opportunity to comment on the December 2011 draft Action Agenda. The City of
Seattle strongly supports the mission of the Puget Sound Partnership; we recognize the critical need
for collective, focused action to protect and restore Puget Sound. As with past comments we’ve
provided to the Partnership, the comments below are the opinions of professional and technical staff
of the City of Seattle (Seattle Public Utilities, Seattle City Light and the Department of Planning and
Development), rather than a statement of official City policy. I would also note that these comments
do not constitute a comprehensive review of the draft document. They are a mix of overarching
comments and specific observations on some elements relevant to the work of our staff that were
able to provide feedback. We hope these, as well as the comments of the South Central Action Area
Caucus (where we participate) will be helpful as the final document is completed.

Clarity. We appreciate the many hours of hard work by Partnership staff, their dedication to the task
of saving Puget Sound and the comprehensive consultation with experts and interested parties that
went into the adoption of targets and the creation of the draft Action Agenda. The draft reflects the
challenges inherent in undertaking a task of this magnitude. However, at this stage, we have
concerns about the ability of this document to provide a clear path forward. The draft Action
Agenda is too lengthy, complex and process-oriented. We believe the Action Agenda should be
simplified, shortened and focused, providing a prioritized plan, with a list of actions that need to be
completed first to protect and restore the most sensitive and threatened ecosystems. The list should
identify exactly what it will take to move forward on these key actions; for example, where new
funding, legislative action, political will and community support is needed, where enforcement of
existing law must be improved, where ongoing work needs to be recognized and supported, and who
will truly be a “lead agency” for any particular new action, as well as who will be partners in that
action.
On behalf of the South Central Action Area Caucus Group, we appreciate the opportunity to submit comments on the
December 9, 2011 draft Action Agenda Update. There has been a tremendous effort to organize the information contained
within this living document, and it is a demonstration of the Puget Sound Partnership’s commitment to recover Puget Sound
through partnership with local entities.
The South Central Action Area includes WRIAs 8, 9, and 10/12 and encompasses highly developed urban areas, rural areas,
and resource lands of King and Pierce Counties. Last year our Local Integrating Organization (Caucus Group) spent
considerable time working through the actions in the original Action Agenda to identify local priorities. In October we
translated that work into a letter and local action table and summarized our highest priorities for inclusion in the Action
Agenda Update. We also tried to make clear that “local” priorities for our action area include not only on-the-ground projects
within our local area, but also Sound-wide actions by state agencies to tie standards for stormwater, shorelines, and floodplain
management to recovery targets.
This letter today adds to the conversation we began in October. We were hoping to see integration of local priorities
throughout the Action Agenda along with clear strategies and priorities for implementation. Integration of local actions could
still be stronger and folded into the overall prioritization process. For example, a blanket near-term action calling for
implementation of watershed-based salmon recovery plans should be added and folded into the overall prioritization process.
As the Local Integrating Organization for the South Central Action Area, the Caucus Group is interested in providing thorough
and specific comments; however, our membership has only had the opportunity to meet once since the release of the Action
Agenda. Given the complexity and length of the document, the Caucus Group members have spent significant time providing
comments on behalf of their own jurisdictions and organizations. What follows is a list of common themes across our
membership. We respectfully request that you consider providing the Local Integrating Organizations with the opportunity to
provide additional comments on the Action Agenda now that members have had a chance to “digest” the Action Agenda and
respond individually.
The following comments are from our January 9, 2012 Caucus Group meeting and reflect the common themes across our
member’s response to the Action Agenda to date:
•Reduce the list of Near Term actions and clarify the framework for implementation: We appreciate the work done to
establish a near term action (NTA) prioritization process that is information-based, transparent and replicable; however, we
have significant concerns about the large number of NTAs and the lack of a clear, short list of priorities that can galvanize
collective action by local governments, state agencies, tribes, NGOs and citizens.
Page 2
General Comment: After reviewing the 2012 Draft Action Agenda, we noticed that many items within
the document are missing (e.g., “To be determined”, etc.). Knowing this, the Strait ERN requests the
opportunity
to comment on these missing items, where appropriate and within the context of the entire 2012
Action Agenda document, as these items become available for review.

p. 22 Strategic Initiatives
General Comment: As the LIO for the Strait Action Area, the Strait ERN looks forward to working with
the Partnership to both better understand and to help identify and implement Strategic Initiatives as
part of the
Action Agenda. To start that work, we propose that 5 of the 6 Strait ERN “packaged” Local Near Term
Actions (LNTA) and the associated specific Priority Actions (listed within Appendix D, NTA Table), be
included as part 1 of the example Strategic Initiatives listed within this section. In addition, the Strait
ERN proposes that the broader needs of habitat protection should be considered, hence the addition
of groundfish within the example Strategic Initiative titled “Protection of habitat in support of
salmon and groundfish recovery” shown below. The Strait ERN “packaged” LNTAs proposed for
inclusion here are listed below for convenience under the appropriate example Strategic Initiative:

*See pages 2-3 for additional comments on Strategic Initiatives

When the people in charge are doing there best to corporatize Puget Sound what good do grants
do? The shell fish industry is killing puget Sound but you are all about encouraging it. I find it difficult
to take you at all seriously.
The Upper Skagit Indian Tribe, a federally recognized Indian Tribe with adjudicated Treaty
Rights, ("Tribe") appreciates the effort and collaboration put forth by the Puget Sound
Partnership ("Partnership") to date, and the Action Agenda represents a significant body of work.
The document is lengthy, and complex therefore the Tribe offers these preliminary comments based
on the limited review and draft status of the document. The Tribe also envisions the Action Agenda
as an adaptable living document, driven by resource protection empirical needs.

Of paramount concern to the Tribe is the manner in which formal consultation, on a government to
government basis, is to be conducted with State as to issues presented by the Action Agenda items.
There has not been a clear expression of what responsibilities, from a Tribal Co-Management
perspective, have been delegated by the State through RCW 90.71 et.seq. or otherwise, to the
Partnership. This clarification is imperative in order to ensure that the Tribe is consulting with the
Partnership on resource issues it has Co-Management authority over; as opposed to WDFW or the
Department of Ecology for example. Although the Tribe has participated in various meetings and has
submitted comments on the recovery plan it does not acquiesce, in any manner, to the Partnership
its Co-Management authority to its Treaty protected resources. Furthermore similar to the
comments expressed by the Tribe in its comments of June 3, 2005 regarding the Chinook recovery
plan, the Action Agenda is incomplete and has a number of placeholders that make it difficult, at
best, for the Tribe to provide meaningful comments. It is critical for the Partnership to understand
the legal standing of the Tribe as a Co-Manager and to engage with the Tribe on a government to
government basis. Although the Tribe has not reached a position as to its participation in a LIO it will
not participate in a forum that elevates other entities who are not Co-Managers to equal standing as
the Tribe. The Tribe's participation in the process in no way alleviates the federal obligation owed to
First, we want to thank you for the work you are doing to lead the development of a strategic plan
for restoring Puget Sound and for focusing on the watersheds that feed it.
We would also like to highlight that the U.S. Fish and Wildlife Service continues to make meaningful
contributions to the recovery of Puget Sound through various programs administered from our
Washington Fish and Wildlife Office as well as from our Regional Office in Portland, Oregon and our
national office in Washington D. C.
For example, here at the Washington Fish and Wildlife Office in Lacey, we have refocused our Puget
Sound Coastal Program on Puget Sound. Previously we had devoted a small proportion of our staff’s
time in Southwest Washington, specifically Willapa Bay. We made this change to contribute to the
restoration momentum building in Puget Sound.
Also, our Washington Fish and Wildlife Office continues to devote significant staff resources to the
development, with our state partners, of grant proposals for our National Coastal Wetlands
Conservation Grants program, which is run out of our Regional Office. For example, this year
through Service’s National Coastal Wetland Conservation Grant program, nine high priority
protection and restoration projects will receive over $7.41M to protect and restore 1,127 acres of
coastal habitats and over one mile of shoreline in Puget Sound.

Federal Contributions to Puget Sound Recovery
Overall it seems the Action Agenda has limited information on Federal Agency involvement and
support, or tasks and expectations. We believe it is important to note what federal programs are
The following are individual comments added to the form emails submitted via Sierra Club. See "Via Sierra Club" link under public comments for a
list of who said what.

3. We have to take actions to save the future.

4. BE THE EXAMPLE OTHER STATES AND COMMUNITIES FOLLOW.

5. We live in a special place. The one thing that makes Washington so special is that we have been able to protect our natural assets. We have
kept them natural. I was just to the Galapagos Islands with several Americans. They were awed by the special state of Galapagos. My favorite
part of the trip is that I realized how special our Puget Sound area is compared with the rest of the country. We are special. So help us stay that
way.

6. I'm sure that you recognize that…We must insist that decision makers consider the high priority of Indigenous Peoples' right to take fish for
living…

7. We need to look at all sides of what is happening. If one part of the problem is ignored then the solution will never be achieved. This changing
climate affects all: the waters, the salmon, the bears, the bees, the flowers and trees, the birds, the tiniest and biggest bugs and creatures the
whales and all ocean life and Us, people. Educate all of us on better daily living choices and ways of living to help restore and heal our nature and
earth.

8. It’s already later than it should be to act on these changes. Please do everything possible to look after Puget Sound.

13. Let's get going before it's too late. Time is precious, we all know that. People and life over money - let's go.



18. Protection needs to begin BEFORE there's a real problem.

19. We have the amazing good fortune to live in such a rich, life sustaining environment. We must employ our most astute intention, clarity, and
care in helping our natural habitat make it through the changes that are upon us!

24. As one involved with many civic activities, I rely on those folk that have a far greater knowledge than I about The Sound. A primary reason I
migrated here is the beauty and life forms in the sound. It is time to take a non corporate benefit aspect of protection of The Sound. Proper
reporting and follow up by citizens must be a vital part of any long range efforts. Respectfully

27. 1990's Washington considered prime outdoor state. 2000's Drastic reduction yearly on result of Salmon fishing, example... 2010's Almost
non existance of fishes in lots of popular area.. bottome feeding seafood caused many increase in human cancer level. Result from the earlier
accumulation of raw sewage dump on Puget Sound water. Determine yourself, the reduction and no more outdoor sea creatures around Puget
Sound is noticeable in yearly outcome. Just consider if outdoor supreme creatures like fish, crustesians are near gone and also bring alert danger
of cancer by all the dumpage of sewer around the Puget sound. The rest of other negative factore is icing on the cake. It's for your own future
water enjoyment and preventing the inevitable of destroying Puget Sound by one by one.... It;s no brainer. Do something or extinct, including
yourself later.....work smarter now, or regret.....
On behalf of farmers and ranchers across Washington state and our more than 41,000 member
families, I would like to thank you for the opportunity to comment on the Draft Action Agenda
update for the Puget Sound Partnership, a 523-page document that most citizens and leaders of this
state will find too lengthy and too detailed to read.
Having been an elected official responsible for oversight of a school district and a county, I can
assure you that even the most committed and policy-oriented public servants will find this document
to be little more than a door-stop or shelf rock. The size of this document is perhaps as much of a
hindrance to its acceptance as is some of the focus and content.
On Page 4 of the draft executive summary, one of the three example initiatives is listed as
“protection of water quality and nearshore habitat from rural and agricultural runoff.” But there
does not appear to be discussion of assessment and first establishing factual information on
existence and sources of such runoff.
For decades, I have seen agencies rush to implement programs to correct actions without first
establishing the existence, extent and source of the problems. The most likely result of this approach
is resentment and suspicion from the very people who are needed as partners. State agencies were
recently reported as being off by significant factors in their portrayal of pollutant in Puget Sound.
This has brought into question the credibility of the data, science and promoters of actions that have
been portrayed as necessary to avoid a crisis. Credible data, science and administration are
necessary to engage the full public in actions.
One of the “proposed priority science questions from 2011-2013” (p. 5) is to “use social science to
guide development of adaptive management structures that can effectively link restoration science
to management decision-making.” Which social science(s) are referred to? Economics? History?
Political science? Psychology? Sociology? This statement is simply unclear and can lead some to
suspect the actual goals are being intentionally made vague.
Thank you for the opportunity to review the 2012 Action Agenda update. Our comments focus
primarily on defining the contribution of Washington Sea Grant (WSG) to the protection and
restoration of Puget Sound and offer suggestions to update, clarify, and expand our inclusion in the
Action Agenda.
Based at the University of Washington, WSG has worked for more that 40 years to support Puget
Sound research, provide technical assistance and translate university science to serve those who
manage, use and enjoy Washington’s oceans and coasts. At the present time we have eight full-time
staff with almost a century of combined experience working with the public in Puget Sound on
practical ways to reduce toxic pollution, restore habitat and promote eco-friendly practices for
businesses and residents. Much of our work is conducted in cooperation with the Partnership and is
authorized jointly with Washington State University (WSU) Extension in ESSB 5372. WSG technical
experts work in almost every county around the Sound and look forward to continuing to work with
you in achieving protection and restoration of Puget Sound.
WSG is actively involved in several of the 2008 Action Agenda near term actions currently underway
in the 2011-2013 biennium. We were pleased to find reference to some of our programs in the
ongoing programs sections of the 2012 Action Agenda update and look forward to meeting with
Partnership Performance Measure staff toconservationrelevant WSGheadquartered in Duvall, near
Wild Fish Conservancy (WFC), a nonprofit ensure that organization activities are included in WA,
offers the following comments on the draft Action Agenda. WFC is dedicated to the recovery and
conservation of the region’s wild-fish ecosystems. Through science, education, and advocacy, WFC
promotes technically and socially responsible habitat, hatchery and harvest management to better
sustain the region’s wild-fish heritage. Specific suggestions for the Partnership or for revisions to the
Action Agenda are in bold.

We appreciate the opportunity to comment. We believe that the Partnership should prepare a
responsiveness summary to the public comments it receives on the draft Action Agenda. If you or
your staff have any questions, please direct them to Mark Hersh of my staff. He can be reached at
425-788-1167 or via email mark@wildfishconservancy.org. Thank you.
Members of the WRIA 16 Watershed Planning Unit are pleased to submit comments on the Puget
Sound Partnership’s draft Action Agenda (AA). The AA is very long and filled with much information.
Because of its length, it is difficult to review and provide relevant input. We hope that you will be
able to add an executive summary in the next draft that will be easier for the public to read and
understand.
The AA includes many good actions. We are especially pleased to see that some of our previous
comments have been addressed. The Planning Unit strongly believes in the value of local input and
we hope there are more opportunities for the Partnership to collaborate with local experts and
agencies. It is very common, particularly in rural areas, for state or regional experts to rely on
incomplete or inaccurate information because they are not familiar with the local environment and
don’t have local contacts for ground-truthing the data. We believe that watershed planning and
implementation groups offer this local expertise and hope that the Partnership is taking advantage
of the expertise offered by these groups throughout Puget Sound. Also, implementing the local
watershed plans will get us a long way toward implementing the AA. These plans provide local,
bottom-up input and oversight.
Support for 2008-09 Action Agenda
The WRIA 16 Planning Unit strongly supports nearly all of the actions included in the original Action
Agenda. As the Partnership works on an update, the Planning Unit would like to see the following:
• What is the status of actions in the original Action Agenda? Please describe progress made and
note any measurable results. If no progress is noted, please elaborate on whether this is because the
action has not started, because no data are available to measure progress, or because the action has
failed to achieve desired results.
• Please highlight all NEW actions that are being added to the Action Agenda and note the reasoning
for the action, how progress will be measured, and when results should be expected.
• Please also note any actions in the original Action Agenda that are being deleted or substantially
revised and explain the reasoning.

Other General Comments
• We are confused by the action area profiles within the AA. They are very inconsistent in format,
content, and level of detail. We would like to see the AA broken out by action area, rather than
having seemingly opportunity disconnected sections for each action Action Agenda. I confused
Thank you for theseparate andto comment on the draft update to thearea. We are alsoam writingby
you in my capacity as Chair of the Lake Washington/Cedar/Sammamish Watershed (WRIA 8) Salmon
Recovery Council which is comprised of 27 local governments, businesses, community groups,
concerned citizens and state and federal agencies who have been working together since 2000 to
recover Chinook salmon in our watershed. Our effort is part of the overall regional effort to recover
listed Puget Sound Chinook salmon.
Recovering salmon populations is critical to restoring the health of Puget Sound. We believe an
important goal for updating the Action Agenda is to better integrate salmon recovery priorities from
the Puget Sound Salmon Recovery Plan into the Action Agenda strategies. We are encouraged that
the draft Action Agenda update reflects this integration much more clearly than the original Action
Agenda. We also appreciate that the funding strategy includes development of a legislative strategy
to adopt a local funding mechanism and acknowledges the collaborative work of the South Central
Puget Sound salmon recovery watersheds on assessing watershed-based funding mechanisms. This
effort originated out of frustration with inadequate funding for implementing salmon recovery plans,
and securing additional, stable, predictable funding to help keep salmon recovery on track is an
important component of a robust, integrated funding strategy for Puget Sound recovery. Federal,
state, and local funding all need to work together to meet the challenges we face to recovery salmon
and restore Puget Sound
We recommend that implementation of the Puget Sound Salmon Recovery Plan be clearly identified
as one of the strategic initiatives identified in the Action Agenda update. As written currently the
habitat protection strategic initiative encompasses some of what must be done for the
On behalf of the WRIA 9 Watershed Ecosystem Forum, the citizen’s group overseeing
implementation of the Chinook salmon recovery plan for the Green/Duwamish and Central Puget
Sound Watershed, I am providing comments on the December 9, 2011 Draft Update to the Puget
Sound Action Agenda.

We greatly appreciate that the Puget Sound Partnership efforts to improve upon the previous Action
Agenda with new recovery targets, a more robust set of strategies and clearer, more measurable
actions, a clearer scientific basis, a better start at distinguishing ongoing programs to protect and
clean up Puget Sound. The work of the Puget Sound Partnership is highly valued by WRIA 9 and that
is why we are pleased to provide the following comments that we hope are found helpful and
demonstrate our commitment to partner with the state in making Puget Sound healthy.

We are particularly pleased to see that the Update makes explicit inclusion of local priorities and
actions and recognizes the critical role that local governments and our many stakeholders play in
protecting and restoring Puget Sound. The update, however, falls short in showing a clear path to
achieve salmon recovery in our and other watersheds.

(specific topic area comments)

The Update needs to not only talk about how local areas are working together at the Local
Implementing Organization (LIO) scale, but more importantly it must provide a clear path for
implementing actions. As the Update states on page 301, the scale of the ILO’s geography makes the
most sense for Action Agenda implementation. For example, in the case of the South Central Action
Area in which WRIA 9 is an active LIO participant, we have worked very hard to identify:
• 10 priority strategies;
The WSAC Coastal Caucus has been watching with great interest as the revised Action Agenda has
progressed. Counties have a variety of responsibilities under state law. While we want to do as much
as we can to protect and restore Puget Sound, we also need to be able to carry out all of our other
duties in a time of scarce funding. In that spirit, we offer the following general comments:
1. There are still a large number of Near Term Actions (NTAs). We understand the prioritization
process, which occurs after the close of the comment period, is intended to reduce this number to a
more manageable size. We believe it is very important to have a smaller number of NTAs in order to
have a realistic, attainable list of tasks to focus on during this next two-year window.
2. For each NTA, there is a column on “owner” and “secondary owner”. There should also be a
column listing the implementers of each action. Local government is often a major implementer, yet
is not specifically mentioned in many of them.

Counties are ready to carry out their responsibilities to protect and restore Puget Sound. As we have
discussed with the Partnership on a number of occasions, we are continuing to face serious budget
shortfalls due to the downturn in the economy. We will need financial assistance to carry out new
responsibilities and ask for your continued attention in this arena. Agenda and Near Term Actions;
Thank you for the opportunity to comment on the draft 2012 Action
the Puget Sound Partnership had a daunting task updating this document. WSDA’s comments focus
on both the need for the Puget Sound Partnership to engage agricultural stakeholders to develop a
comprehensive agricultural strategy for Puget Sound and the need for clarification of Near Term
Actions attributed to WSDA.

The draft Action Agenda has an emphasis on regulatory and stewardship programs related to
agriculture and very little discussion of the pressures the agricultural community face to remain
viable within the Puget Sound basin. Staff who participated in the Action Agenda workshops noted
they were often the only participants with an agricultural background. Based on this feedback, I am
concerned that the interests of agricultural stakeholders are not adequately represented in the
Action Agenda.
Hood Canal:
- We are very pleased to see working with WRIA planning units to implement priority actions
specifically included in the Hood Canal section. In particular, we are pleased that Phases II and III of
our water demand, supply, and availability study are included as priority actions.
- We suggest including implementation of existing plans to create wastewater infrastructure, such as
the Dosewallips and Port Hadlock sewers, as a priority action. In so doing, the region should learn
from new wastewater projects such as that in Belfair.
- Action A and Action B under Wastewater are no longer defined, perhaps because of changes in
formatting.
- Please change the listing for the WRIA 17/East Jefferson Watershed Council’s website to our
website, rather than Ecology’s (or list both): http://www.ejwc.org.
• Identification of Hood Canal’s natural oceanographic conditions leading to poor water quality
should be described in the context of challenges to improving water quality or rationale for stricter
nutrient loading standards, not just stated.
• The chapter mentions displacement of Olympic oysters with Pacific oysters but includes no
statement about the effect on the ecosystem of the canal, especially interspecific competition that
might prevent Olympia oyster recovery.
• IWMP acronym not spelled out or defined.
• SKIA acronym not spelled out or defined
• Organization of the chapter could be improved. HCCC, its role and membership should be
foremost in the chapter with some documentation that there was an assertion from the PSP staff,
Leadership Council or some other body in sanctifying the HCCC as the LIO. Section 1 of the main
Action Agenda does this but a local perspective on why HCCC is the appropriate group to be the LIO
would be welcome here as well. It would be more useful for there to be a glossary of acronyms used
in the text than to have 3 pages of random agency and organization links. Links to key partners with
the LCCC in developing the local strategy should be highlighted, not that full list. The chapter lacks a
sense of prioritization orOrganizations and local leads for both the Hood Canal Action Area and
The Local Implementing basis in science as to what are the most pressing issues to address first,
North Central Puget Sound Action Area have listed the features represented by the Port Gamble
project as a high priority in their draft submissions for the Action Agenda Update. The North
Central/West Sound Action Area, specifically lists the project as a top priority:

Support Kitsap Forest and Bay Project - a shoreline and forest conservation project spanning from
near the Carpenter Creek Estuary and including 7,000 acres of forest and 1.5 miles of shoreline on
Port Gamble Bay. This spans two action areas.
Please add Lower Hood Canal Watershed Coalition to the Hood Canal Action Area partners list.

The current updating of the Action Agenda and associated comment period has allowed for a great
opportunity to engage with our Hood Canal community partners in an exchange of information and
ideas to address what threatens Hood Canal. Your process has sharpened the focus on these critical
issues and mobilized community involvement. Through our Integrated Watershed Management
Plan (IWMP) approach we have been working closely with our partners and their comments reflect
the direction and guidance of the IWMP and goals established for the Hood Canal Action Area. As
the Local Integrating Organization (LIO), we recognize that more work is needed with our partners to
further develop and incorporate recommendations into the IWMP and the Action Agenda over the
next couple of months. We will use all comments that pertain, to refine the local Hood Canal near
term actions (NTAs). As together we get a better handle on the breadth, depth, and scope of the
comments, we will want to be involved in editing and updating the local Hood Canal profile and will
work with Partnership staff to accomplish this task. We also seek to understand how the regional
Puget Sound NTAs will support these local NTAs.
The Hood Canal Environmental Council (HCEC) has worked to protect the Hood Canal watershed’s
environmental health since 1969. During this time, our members and others have been involved in
numerous planning efforts, always working toward the goals of protections and restoration of water
quality and related natural resources. HCEC members and others have followed the development of
the Integrated Watershed Management Plan (IWMP) for the Hood Canal area with particular
interest. We are generally supportive of the list of strategies and actions spelled out in the “Action
Agenda in Hood Canal.” We believe that the continued IWMP process currently represents the
greatest chance of accomplishing our goals for this watershed.

As the Local Integrating Organization for the Hood Canal Action Area, the Hood Canal Coordinating
Council (HCCC) deserves credit for guiding the IWMP planning process. The HCCC and its effective
partnerships have worked hard through this process to develop a comprehensive list of strategies
and actions listed in the Hood Canal profile section of the Puget Sound Partnership (PSP) draft
update document. In particular, the HCEC supports the following actions:

• Implement and enforce existing regulatory programs of the counties (SMP, CAO, Comprehensive
Plans, etc.) and states (RCW’s and WAC’s). Adequate funding here will be critical. Mason County
recently received grant money for compliance and enforcement activities for existing laws and
regulations. This action assists in the implementation of several WRIA 16 Planning Unit
recommendations outlined in its WMP.
• Permanently protect larger tracts of forests for their forest (ecological and community) values.
HCEC is actively involved in the Great Kitsap Forest and Bay Project in seeking to conserve as much as
7,000 acres of forestland and 2 miles of Port Gamble Bay shoreline in North Kitsap County. Raising
the needed funds to buy the land will take considerable support and involvement of public agencies
These comments track the text of the draft Action Agenda in Hood Canal. Reference to page and section of text is provided in order to effectively
re-locate the original text. There are instances where the current text requires some clarity and those sections were pulled out. The most
significant omission is related to the accomplishments and information gaps posed by the Hood Canal Dissolved Oxygen Program (HCDOP). A
significant amount of current action given to Hood Canal can be attributed to the investigation of the HCDOP. Over 40 regional partners (federal,
state, county, tribal, NGOs, businesses, communities) contributed to the science portion of the program, and HCDOP currently continues primarily
as corrective action discussions through technical committees organized by the Hood Canal Coordinating Council. One of the greatest assets to
the HCDOP has been the marine monitoring program which consists of a network of moorings combined with a citizen monitoring program.
The datasets derived from these monitoring assets has provided the analysis of forces and conditions contributing to the low dissolved oxygen
conditions. The results of the analysis are in part guiding current and proposed corrective actions. Although the HCDOP has helped to guide
corrective actions to this point, the need for greater resolution in measurements of OSS nitrogen removal, shoreline groundwater seeps, and
refinement of watershed modeling is critical for evolving our knowledge.
The network of monitoring assets established by HCDOP continues to be vital in evaluating corrective actions (such as sewer systems) as well as
evaluating the variability within seasonal conditions.
The network of marine monitoring has also been consistently uses as a tool for investigations related to the effects of low dissolved oxygen on
the biota, relationships with phytoplankton communities, sediment analysis, and food web relationships. The current Action Agenda in Hood
Canal does not reflect the essential need to maintain the network of marine monitoring.

Accomplishments (Local Area Actions - page 305 inset)
One of the most significant ‘accomplishments’ related to Hood Canal is the Hood Canal Dissolved Oxygen Program investigative study on the
causes and implications of chronic and episodic low dissolved oxygen. This is missing in the list of accomplishments!
 Unique ecosystem characteristics and assets (Local Area Actions - page 305 text)
For the purpose of describing and subsequently working to address ecological issues in Hood Canal, it is important to describe the “Unique
ecosystem characteristics and assets” of lower Hood Canal separate from the rest of Hood Canal. Stating the “The human population of the Hood
Canal region is low” is misleading when considering the development density around the shoreline of Lynch Cove and lower Hood Canal. The
anthropogenic contributions in this region influence the low dissolved oxygen concentrations as well as closed shellfish beds.
Note: Two of the most important water quality issues in Hood Canal are the annual development of low dissolved oxygen concentrations, and the
chronic levels of Fecal coliform bacteria which restrict the harvest of shellfish.
Text change consideration (Local Area Actions - page 306 text): Orca whales do not “frequent Hood Canal to feed on prey species indigenous to
Hood Canal. “ The only Orca whales to recently enter Hood Canal (2003, 2005) were the transient Orca subspecies which only eats seals. In 2003,
eleven transient Orcas spent two months, and in 2005 six transient Orcas spent four months in Hood Canal, at times traveling as far as Twanoh
State Park in lower Hood Canal. According to biologist, the duration of these events were unusual.
Text change consideration (Local Area Actions - page 306 text): There are no old growth forest in close proximity to the marine shoreline which
“provides unique habitats for many bird species and mammals”. Small fragments of old growth forest remain in a few locations of the watershed
which help to sustain some animal species which rely on this habitat type.
Text change consideration (Local Area Actions - page 306 text): Not sure what is meant by; “Year-round and seasonal residents and visitors work
hard to understand the physical and biological conditions that affect Hood Canal”. Hood Canal is a blend of long-term residence, residents
transplanted from other places, and seasonal residents and visitors which recreate. It is an enormous challenge to provide ecological as well as
socio-economic messages to a widespread and diverse populace. There are significant “physical and biological conditions” which need to be
communicated to the Hood Canal public.
We are writing to request your assistance to have the Port Hadlock Wastewater Treatment Facility
Project relisted on the Puget Sound Partnership's Action Agenda list. Until now, the project has been
on the Action Agenda list, which has emphasized the project's importance for local government
support and also helped us to receive a federal State and Tribal Assistance Grant (STAG) with
Congressman Dicks' support. Further, the fact that the project has been on the list has enabled us to
highlight the Action Agenda, and provides important recognition of the planned facility at public
meetings where we have gained citizen support and built momentum for the project.

Jefferson County has been a responsible leader in developing this project as a means of
environmental restoration and of managing the growth that is occurring in the County. The project is
active and moving forward and the community has made a very strong commitment of tax dollar
support to the project, including sale of a $2.2 million bond package in 2011 to advance the project.

Project milestones that the County has reached to date include:

• Considerable outreach has taken place in the community to build local public support.
• With Congressman Dicks support for the project, Jefferson County was able to secure a $1,000,000
STAG grant.
• Significant County tax dollars have been dedicated to the project including a $2.2 million bond sale
in 2011.
• The project received a $10,000,000 dollar loan from the Public Works Trust Fund.
• The County has acquired much of the land needed for the project and is pursuing the remainder.
• Just in the last month the project met a major milestone when it delivered the 30% plans,
specifications, and estimates for the Water Reclamation Facility.

The project makes a significant contribution in the effort to clean-up Hood Canal and the
environment.
In addition to substantially addressing fecal coliform, nitrates, and other pollutants, the project
recharges water into the Chimacum Creek aquifer that will help with salmon restoration.

Itam a our understanding that County working on the Port Hadlock NewFacility Project would remain
I was consultant to Jefferson the Port Hadlock Wastewater Treatment Wastewater Facility/Reuse
Project for the Port Hadlock UGA in Jefferson County. A Facility Plan has been approved by DOE and
preliminary design is nearly complete. I reviewed the near term solutions in both Hood Canal and
Strait of Juan de Fuca action areas and did not see any mention of this high priority project. I did
notice that the Carlsborg UGA new wastewater facility/reuse project in Clallam County is clearly
listed. Who can I check with to determine why the Port Hadlock project is not listed?
Please find attached a cover letter noting other recipients of the Near Term Actions identified by the
Lower hood Canal Watershed Coalition
(LHCWC) to be integrated into the Hood Canal Action Area section of the Action Agenda Update.
Enclosed are the priority Near Term Actions identified by the Lower Hood Canal Watershed Coalition
(LHCWC). These Actions need to be integrated into the 2012 Puget Sound Action Agenda Update.

The Hood Canal Action Area is characterized for having two chronic problems: (A) intermittent low
dissolved oxygen levels in the marine water stressing and/or killing marine life and (B) shellfish
harvest and beach closures due to known or potential risk of pathogen contamination.

A. Low Dissolved Oxygen Levels
The EPA and PSP have set a target of no more than 0.2 ppm of dissolved oxygen reduction due to
human activity anywhere in Puget Sound by 2020.
Background
The low dissolved oxygen levels measured in the marine water and the observed marine life stress
results from the growth of phytoplankton fueled by nitrogen and sunlight which eventually dies,
sinks and decays using up dissolved oxygen in the marine water. The nitrogen fueling the
phytoplankton growth comes from human activities such as on-site septic systems and stormwater
runoff (fertilizers, pet waste), but primarily from ocean water inflow.
Strategy D SubTask 4 Text: Implement a strategic science and regional monitoring program that
improves decisions about how to protect restore Puget Sound
Near Term Action #
Owners UW-Applied Physics Lab, Hood Canal Salmon Enhancement Group
Performance Measures Monthly or Quarterly reports April 2012 through 2020
1. Continue the current marine water monitoring using the ORCA buoys and monthly citizen-
monitoring program through 2020. This monitoring is required to determine the seasonal dissolved
oxygen drawdown in the lower Hood Canal, the amount of human- related nitrogen reduction
needed to meet the target and verify the improvement toward the target. Note: The current
funding ends in March 2012. Need to add additional nearshore monitoring for nitrogen sites.
Cost- $300,000 per year
Regarding Hood Canal / Case inlet: actions on low dissolved oxygen levels and shellfish harvest
SEE LETTER for nine more suggested
The focus should be developing / expanding sewer systems. The people / houses / septic systems are
there. Nothing is going to change this fact. Assisting Mason County in developing a phase two and
three of the sewer system would be a good start. Another possibility would be to expand the Allyn
system to include more of Case Inlet.
Hold Hood Canal climate change symposium to develop, refine and prioritize strategies. What type of
climate change are we anticipating? How will this change the fact that nitrogen is flowing into Hood
Canal. Low dissolved O2 has been documented in Hood Canal since the 1940’s. The symposium
should be to bring community leaders together to assist with fecal / high nitrogen – let’s leave global
warming / climate change to a more national conversation. This should not be any kind of priority.
Hood Canal Action Area

The Hood Canal Coordinating Council (HCCC) is a watershed-based council of governments,
comprised of Jefferson, Mason and Kitsap County Commissioners, and Skokomish and Port Gamble
S’Klallam Tribal leaders, and HCCC is the LIO for the Hood Canal Action Area. The HCCC is developing
an Integrated Watershed Management Plan (IWMP) for Hood Canal and, at the same time,
developed and facilitated a process to identify strategies and actions which will help inform the
update of the Action Agenda. Staff from the JKT, PGT, and PNPTC regularly attended and
participated in the development of the IWMP and Action Agenda.
Prioritization of actions still needs to be completed for the IWMP and the Action Agenda, but the
processes did identify the strategies and actions which addressed ‘very high’ and ‘high’
pressures/threats in the Hood Canal region. We have attached a draft of the IWMP and Action
Agenda Update which provides (1) a good focus for prioritization efforts and (2) a good ‘crosswalk’
between the IWMP and the strategies and Near Term Actions in the Action Agenda.

We suggest that the Partnership consider including the attached table as part of the Hood Canal
Profile. We further suggest that implementation of the Local Near Term Actions (LNTAs) identified
and presented in the attached IWMP and Action Agenda Update will contribute substantially to the
p. 304 - Please correct the Hood Canal Action Area map to include the Port Gamble S’Klallam Tribe’s
reservation. The existing map in the Draft Action Agenda Update incorrectly identifies the area as
“Federal, State, Local publically owned land”.

See the Port Gamble S’Klallam Tribe website for a map of the Reservation area:
http://www.pgst.nsn.us/contact-info-a-directions

p.307 -310 - The priority strategies in the 2009 Action Agenda Hood Canal Profile included “prioritize
inwater and upland toxic cleanup sites: Clean up industrial pollution in Port Gamble Bay.” However,
this action has been dropped from the 2011 Draft Action Agenda Update.

The Hood Canal Opportunities, Priorities and Near Term Actions section of the Action Agenda
Update should continue to include the Port Gamble Bay cleanup as a priority near term action.
Under the State’s Model Toxics Control Act (MTCA), Port Gamble Bay is a priority cleanup site under
the Puget Sound Initiative. The Washington Department of Ecology is currently developing a MTCA
cleanup plan for the site.
http://www.ecy.wa.gov/programs/tcp/sites_brochure/psi/overview/psi_baywide.html

p. 307 -310 - The Hood Canal Opportunities, Priorities and Near Term Actions should more explicitly
identify the North Kitsap Forest and Bay conservation project as a near term strategy.

We suggest the following language: “Forterra, working on behalf of Kitsap County, the Port Gamble
S’Klallam Tribe and the Suquamish Tribe, will coordinate funding and agency participation to secure
the conservation of land near Port Gamble bay, including almost 2 miles of shoreline within the next
30 months.”

This near term action will permanently protect water quality and nearshore habitat in Port Gamble
The following items should be the highest priority for Hood Canal Near-Term Actions:
Stream Aggradation
Stream aggradation and degradation is a major issue in WRIA 16. Stream beds have risen over 5-10
feet in areas due to aggradation. This results in seasonally-limited surface water going subsurface,
which has dire consequences for salmonid habitat; particularly ESA listed Hood Canal Summer Chum.
There has also been improper development that impairs alluvial systems. The AA should address
how to manage future development so that it does not further impair alluvial processes.
The WRIA 16 Planning Unit conducted a stream impairment study that began to assess this problem
but follow up is needed, particularly a field-based assessment of what is occurring in the uplands that
is causing the aggradation and how this can be mitigated. Additional field assessment of the sources
and amounts of aggradation in individual streams is also needed.
On-Site Septic Systems (OSS) and Other Waste Management Issues
It is important that financing is available for the repair and replacement of failing OSS. There is a
need for adequate seed money for the loan program offered by Craft3 (formerly Enterprise
Cascadia). Continuation of this public-private partnership is extremely important. It is also important
to address the remaining questions about the contribution of OSS to nitrogen loads in the Canal.
There is also a need for adequate sanitary services at popular recreation sites around Hood Canal.
The WRIA 16 Planning Unit has prepared a prioritized list of sites that need services but efforts to
identify public or private funding have not been successful.
Monitoring
Hood Canal needs strong monitoring programs that include:
• Surface water quality and quantity, and
• Groundwater quality and water levels.
There are inadequate data for Hood Canal and monitoring is needed to track trends, measure
progress, and identify emerging problems. Nearly everyone agrees on the need for monitoring but
funding is inadequate. It is important for state, regional, and local entities to work together to find
long-term funding for monitoring efforts, including funds for pollution identification and correction.
Collaboration with Local Agencies and Experts
It is very important that efforts to protect, restore and enhance Hood Canal are completed efficiently
with the best science and data available. Because there are limited data on many aspects of Hood
A8.1-3, All NTAs:
BIAW urges the PSP to carefully consider the implementation of any of these actions. Water --
instream flows, water demand, and exempt wells-- has a long and arduous history and future. The
PSP should acknowledge that domestic use of water is a high priority. Establishing instream flow
rules affect Washington citizens in unanticipated ways. Washington residents must have access to
domestic water usage and PSP attempt to create rules sans legislation will create even more
confusion and open the state and local governments up for litigation. It is troubling that these NTAs
do not address that domestic water use is a high priority. Currently, there are many stakeholders
involved in water allocation issues: the federal, state and local governments, tribes and individual
citizens. BIAW encourages the Partnership to tread very lightly and leave water allocation issues to
those already involved in its regulation. Washington residents do not need more water authorities to
which to answer, as it will only serve to add more perplexity to existing water law.



A.8.1.1
Comment: “Ecology, with support from WDFW, will set flow rules in three remaining Puget Sound
watersheds (WRIA’s 16, 18, and 19). . “ WDFW is secondary owner.Should it be WRIAs 16, 17, and
18? (these are inclusive of West Hood Canal and westward around peninsula to Elwha). This could be
an important action for Chinook and steelhead recovery because to potential for low summer flows
being limiting factors. Steelhead’s presence in freshwater for nearly two years means flow conditions
are particularly critical to survival.
Recommended Edit: Re-assess list of watersheds. Identify WDFW as secondary owner.
Freshwater Flows and Groundwater Protection – A8
Overall comment: this section is highly focused on the Washington State Department of Ecology.
While Ecology plays a critical role in water resource management, they are not the only entity
responsible for managing water. Water right holders, including farmers, public utilities,
municipalities, and Tribes, also manage water on a daily basis. In many WRIAs around Puget Sound,
local multi-stakeholder groups established under RCW 90.82 have created local plans to manage
water quantity, including both surface water and groundwater. The Action Agenda should explicitly
support the implementation of these plans and the continued existence of these robust local groups.
A8 Freshwater Flows and Groundwater Protection
P.84: minor edit, the last sentence of the introductory paragraph under A8 says the strategy
approaches freshwater protection and conservation from three perspectives, and four are listed.
A8.1


backlash from home builders, realtors, and property owners.” This sentence seems pejorative.
Perhaps something more like “New instream flow rules often limit access to groundwater supplies,
raising concerns among home builders, realtors, and property owners.”

sufficient spatial and temporal data on actual water use and the effects of groundwater withdrawal
on stream flows. This lack of data hampers Ecology’s ability to develop and support good instream
flow rules. The ability to show how additional water withdrawals would harm senior water right
users and listed species, with good data from that watershed, would likely help Ecology’s outreach
efforts significantly and increase public trust in the science behind the rules.

performance measures?
Near-Term Actions

water code Subtask 8.3, and enforcement Ecology shouldEast Jefferson Watershed Councilpartners in
Strategy A, compliance NTA#1 (Page 21) by [date]. The consider working with Canadian finds this
the development of groundwater management programs for transboundary aquifers such as the
Abbotsford-Sumas Aquifer. An Environmental Cooperation Agreement was signed by BC and WA in
1992 to create an international task force to coordinate groundwater protection efforts in the
aquifer region.


Page 83. Freshwater Protection. We applaud the Partnership’s continued focus on protecting freshwater as a critical component of Puget Sound
recovery. We note however an organizational issue. Some of the categories that appear to be included within “Freshwater Protection,” such as
Salmon recovery, and Biodiversity, are not related to just freshwater. This can create some confusion for the reader.
Page 84. Water Resources (A8). The order of the strategy seems to be out of sequence in this part of the Action Agenda. The following strategies
– Salmon recovery, Biodiversity, etc. – are not related to just freshwater and thus it is confusing the reader that these are all lumped together and
the order that they are in. We recommend that a new super-category be created with a name along the lines of “Species recovery” and the
relevant substrategies be included there.
Page 84. Update Puget Sound instream flow rules to encourage conservation. (A8.1).
• Instream flow rules are the best tool we have for protection of flows in rivers and streams, but as presently configured and implemented, they
can fall woefully short of achieving the goal of ensuring sufficient water instream to restore and enhance fish and wildlife, and protect water
quality for all uses. Instream flow rules are subordinate to senior rights, and, during water-short periods, instream rights can be curtailed or shut
down altogether. Moreover, many of the instream flow rules adopted for Puget Sound Water Resource Inventory Areas (WRIAs) are not based
upon adequate science, such as instream flow incremental modeling studies. As the Partnership points out, the Kennedy-Goldsborough instream
flow rule dates back to 1988. Ecology or an independent science consultant should assess of the adequacy of the regulatory targets set by the
existing instream rules in the Puget Sound region against river and stream performance, and in particular compliance with the goals of the
Recovery Plans for Puget Sound Chinook and Hood Canal Summer Chum. Based upon that assessment, and up to date science and instream flow
incremental modeling, existing, inadequate instream flow rules should and must be amended as required.
• Moreover, new instream flow rules and updated instream flows rules must integrate groundwater modeling for each WRIA to be scientifically
valid in order to be worthwhile as a regulatory tool and a driver of salmon recovery. During this region’s typically dry summers and early falls,
groundwater is a substantial (and in some streams the sole) contributor to streamflow. Therefore, especially during the critical migration and
spawning periods of summer and fall, we must refrain from consuming the groundwater that feeds and maintains adequate flows for fish. To do
that, the Puget Sound region needs to understand the distribution and extent of its groundwater resources. Ecology needs the resources to
undertake comprehensive groundwater mapping.
• Finally, to achieve the goal implicit in the Partnership’s title for this section, that is, encouraging conservation by updating the instream flow
The Freshwater Protection section has a good description of climate change in the very first
paragraph. This should consideration should be carried through into each action. Climate change
could be mentioned in several places. For example in the third bullet at the bottom of page 88,
climate change could be added to the list of emerging issues and future considerations regarding
water. Summer Stream Flows is another logical place for CC consideration on restored flows (see
below).

Pages 83-89, Freshwater Protection. A quantitative estimate of how much each basic approach
(adoption or updating of instream flow rules; demand management and conservation; etc.) could
contribute to summer stream flow goals would be very helpful in evaluating whether the near-term
actions are appropriate. For example, is demand and use increasing at such a rate that even a high
degree of conservation could not offset increased demand? Climate change is likely to have very
significant effects on in-stream flows, so there should be specific language relating to incorporating
potential climate change effects on the sub-strategies or actions in this section.

A8.2 (pages 87-88) - “Decrease the amount of water withdrawn or diverted and per capita water
use.” This near-term action only involves municipal demand; however, it’s unclear whether
municipal demand is the most significant threat to instream flow. If it is not, near-term actions for
the other significant components (e.g., agricultural and industrial) of demand should be developed.
Page 88, 1st line: Performance measure: dumber of demand management...” change to number. 1st
bullet, 2nd line: currently

A8.3 (page 88) - “Implement effective management programs for groundwater.” Consider a near-
• In the section on Freshwater Protection, the second and third bullets in the discussion of emerging
issues and opportunities (pg. 88) introduce the concept of integrated water planning and budgeting.
This is likely to become increasingly important as the region grapples with future challenges of an
expanding population and climate change. We support the consideration of such an initiative, and
urge that reclaimed water be included as a component.
• NTA1 under A8.3 could be a stronger statement about the problem of exempt wells, as more is
needed beyond a consistent approach to making decisions. This action and the strategy discussion
should also recognize and address the likelihood that climate change is going to have an impact on
flows and groundwater.
NTA A.8.1 would update Puget Sound instream flow rules and encourage conservation. This could
help with the implementation of local RCW 90.58 watershed plans but will be costly for Ecology to
provide the specified number of water master plans. Water supply purveyors are already highly
regulated by Ecology and Department of Health. There are stringent controls on complying with
permitted water rights, leak reduction, water conservation and groundwater protection
requirements to protect both the surface and groundwater resources in the state, including instream
flows.

NTA A.8.2 relating to Water Demand and Water User Conservation would decrease the amount of
water withdrawn or diverted and per capita water use. There are already conservation
requirements, including higher rates for irrigation water meters and water use. This NTA is
duplicative of existing requirements and programs. Local governments and purveyors will need to be
involved in this NTA, especially if the goal is to establish a tiered pricing structure that has to be
implemented within their water service areas.
A.8, General Comment: This section’s title should reflect inclusion of water resources in some way;
changing the title to something like “Freshwater Resource Protection,” would be more indicative of
the content. Issues surrounding water quantity and conservation are included. These subjects are
related to freshwater protection; however, the title seems to misrepresent the content of the
strategy, which communicates sub-strategies relating to freshwater as a resource for human
consumption. (p. 83)
A.8.1 Instream Flows

Comment: A near-term action could be to implement the 2nd order stream monitoring portion of
the S&T for the NPDES

A8.1 Update Puget Sound instream flow rules to encourage conservation

We are particularly interested in the effectiveness of the Instream Flow Rules due to the common
low flow events the Stillaguamish river experiences in the late summer months. Currently, there
appears to be no accountability for the rules. It’s unclear if the rules are working and if their effect is
being measured and documented. The Stillaguamish Tribe encourages the Puget Sound Partnership
to work with the Washington State Department of Ecology to establish measurable goals for the
Instream Flow Rules and a method of accountability toward those goals.

A8.2 Decrease the amount of water withdrawn or diverted and per capita water use.

The Stillaguamish Tribe is deeply concerned about the effect exempt wells have on instream flows.
We encourage the Partnership to work closely with the Washington State Department of Ecology to
implement a solution to this growing problem.

Our Natural Resource Department has been undergoing a process to design and build a new office
facility. During this process, innovative new technologies have been incorporated into the design.
One such technology that was discussed and thoroughly investigated was a rainwater catchment
page 85-Local Strategies insert
Suggestion: Include "adopting" within this sentence: "Specifically, the Strait identified adopting
and/or implementing Instream Flow Rules for..."

page 87 - Local Action insert
Suggestion: Delete this entry as it seems redundant with the Local Strategies insert immediately
above on page 85.
Comment #1. Water acquisition (via water right leases purchases and voluntary agreements with
water right holders) is the primary tool for improving flows in unregulated rivers across Washington
State. We would encourage you to list water acquisition as a key tool for flow enchantment
particularly to address summer low flows. Given that most Puget Sound Basins are considered
overallocated by Department of Ecology, meaning more water rights have been granted than the
actual flow of the stream can support, it is imperative to list water acquisition as a tool for flow
restoration. As an example, Washington Water Trust competed the first permanent purchase of
environmental flow in Western Washington in 2009 on Cascade Creek on Orcas Island.

Comment #2. Addressing low flow challenges in Puget Sound watershed must consider flow issues in
tributaries as well as mainstem rivers. While we understand this is meant as an overview chapter
without too many details, tributary flow can be one of the biggest limiting factors in salmon recovery
and must be addressed by water acquisition or other water management activities. For example in
the Nooksack Basin, while the flows of the mainstem river main not be a challenge for fish, flows in
key tributaries like Bertrand and Fishtrap Creeks are of great concern.

 Instream #3. discussions need to mention role of tribes and local governments. Having two state
Comment flow Dungeness River flows are listed as relatively stable in the action agenda. This metric
agencies listed as the two owners is not acceptable. This section needs to mention the need for
collaboration with WRIAs. Successful implementation of water management rules is dependent on
the cooperation of tribes and local agencies.
In general Priority: ? Although stated as a serious threat to Puget Sound recovery, no logic models include invasive species.
Unclear how this may or may not affect overall application of Action Agenda to reduce threat.

A10.1: Ongoing Programs (Page 102) Priority: HIGH
WDFW conserves and protects native fish and wildlife by:
4. Initiate new and enhancing existing partnerships with conservation, invasive species, and other organizations to help
conserve Washington’s fish and wildlife.
Through adaptive management, the strategy will do the following: [Add new bullet]
• Prevent the introduction of new aquatic invasive species and control or eradicate established populations
Rationale - Approximately 1/3rd of the introductory text is devoted to how invasive species threatens biodiversity, but
“Ongoing Programs,” Actions, and Near-Term Actions do not specifically address this issue. Revised as above, the Near-Term
Actions are then adequately qualified to reflect priority risks.

A10.2: Ongoing Programs (Page 104) Priority: HIGH
[Add new paragraph]
Invaders at the Gate Strategic Plan: The Washington Invasive Species Council (WISC) is the legislatively-established forum to
provide policy-level planning and direction for regional invasive species efforts and coordination, collaboration, and
information sharing among federal, state, tribal, local, and private partners. Their strategic plan sets priorities, identifies gaps
and provides goals, recommendations, and actions to address the significant threat invasive species pose to recovering Puget
Sound. Specific near-term actions to address invasive species for the purposes of this action are identified in A11.1, A11.2,
B8.1, and B8.2.
Rationale - Same as for A10.1 and provide link to WISC notation in bulleted list on page 103. Since there are no NTAs for this
action, it is important to point readers to how this can be addressed.

A11.1: Relationship to Recovery Targets (Page 107) Priority: MODERATE
This section poorly addresses the threats of invasive species to Puget Sound recovery targets. Freshwater insects are only a
small part of the threats that can include loss of habitat, loss of base food levels, and direct physical harm (diseases, parasites,
and zebra/quagga mussels in fish passage facilities). No specific wording recommendation.

A11.1 NTA 2: (Page 109) Priority: MODERATE
The Invasive Species Council, in collaboration with PSP, will begin developing an early detection and monitoring program plan
for priority invasive species in Puget Sound. The Council and PSP will coordinate the plan and implementation efforts with the
Puget Sound Coordinated Ecosystem Monitoring and Assessment Program.
Rationale - Incorrect direction on PSP role for NTA. PSP is a member of WISC and does not have any other specific
responsibility as an agency for this NTA. The key concern is captured in the last sentence on working with the PSCEMAP (Kevin
Anderson, PSP - personal communication).
A11: Invasive Species
A.11.1 NTAs 1-4: Consider combining these actions into one coordinated action with a lead or co-
leads identified (ISC and/or DFW). Consider obtaining coverage under Ecology’s Aquatic Invasive
Species Management General Permit so there is no delay responding to an early detection of an
invasion due to paperwork.

P. 107 We are disappointed by the lack of mention of opportunities for cooperation over invasive
species between BC and Washington. Success stories such as Spartina on the US side and the
ongoing threat from re-infestation from the BC side should be highlighted.


Page 107. Invasive species – general. In addition to the challenges listed, another barrier is that the
various agencies have not created coordinated maps of many of the mapped invasive species
infestations and there are gaps in map coverage. This is especially true for knotweed. This need
should also be noted under A11.1.
A11. Invasive species. It would help to explicitly discuss the role of future CC scenarios on changes,
both positive and negative, in invasive species habitat. This would help with future planning (similar
to other habitat-related evaluations, such as for salmonids).

A11.2, NTA 1 (page 110) - This NTA involves performing a risk assessment to evaluate the
environmental and economic impacts of invasive species, including consideration of climate change.
The completion date for the risk assessment (June 2015, the same as the other NTAs in this section)
should be accelerated. This information will inform how to prioritize all the strategies and actions for
invasive species, including the other NTAs in this section.
Finally, I appreciate that the draft Action Agenda recognizes that invasive species and salmon
recovery are top priorities for Puget Sound recovery. While RCO is not a direct implementer, we
support the important work of the Invasive Species Council and the Governor’s Salmon Recovery
Office, and we provide grant funding to Puget Sound through several programs. I hope invasive
species and salmon recovery remain top priorities through your prioritization process.

A.11 Invasive Species

Comment: All invasive species prevention protocols should be mandatory components of all JARPA
permits.

A11.1 NTA 4: DFW will develop a plan with the objective of limiting the spread of New Zealand mud
snails in the Puget Sound basin.

Comment: Performance measure: Change in the number of known areas or acreage infested with
New Zealand or change in the number of known locations containing mudsnails. The number of sites
has increased – is this an indication of success as the performance measure is currently written?

Invasive Species

A 11.1 NTA 1
The Invasive Species Council will expand its baseline assessment to include an additional 15 of the
Council’s priority invasive species.

A 11.1 NTA.2
The Invasive Species Council, in collaboration with PSP, will begin developing an early detection and
monitoring program plan for priority invasive species in Puget Sound. The Council and PSP will
coordinate the plan and implementation efforts with the Puget Sound Coordinated Ecosystem
Monitoring and Assessment Program.

These NTAs do not mention WSDA; however the plans being developed by WDFW and WISC might
involve organisms that fall under WSDA’s jurisdiction. These NTAs should include language reflecting
collaboration/consultation with WSDA when appropriate.

A11.2 NTA 1/B 8.2 NTA 1
The Washington Invasive Species Council and PSP will initiate a risk assessment to evaluate the
environmental and economic impacts of invasive species in the Puget Sound marine and near shore
ecosystems and incorporate short-term climate change considerations.

Depending on the species identified, WISC and PSP will likely require WSDA expert opinion when
developing this risk assessment. This is an enormous task and WSDA is concerned that adequate
• There is no explanation of why Island County is now a separate or relevant geographic subdivision
of Puget Sound, differs from any oceanographic sub-basin distinction. Population increase projection
is not referenced and out of context. What is the current population of the county?
• Geographic contexting of species and habitats jumps from around the island to “inside of the
island” whatever that means, to the Whidbey Basin, which is a recognized oceanographic sub-basin
of Puget Sound.
• If Port Susan Bay Marine Stewardship Area is important to mention, then so is the Smith/Minor
Island Aquatic Reserve.
Island LIO, Opportunities, Priorities and Near Term Actions (page 319) - This paragraph should be
rewritten to present the process that the Island LIO is using to establish priorities and the steps they
are/will be taking to sequence and prioritize activities. Since some important actions identified are
slated for 2012, it might make sense to remove the reference to the year 2012 and just state these
actions as current or ongoing so that the text isn’t dated immediately after Action Agenda
publication.
p. 319 (Delete) 'Bay' following Port Susan



Permanent Protection of Intact Areas (Section A2):
The draft Action Agenda correctly points out that permanent protection of intact habitat is an
important priority action for recovering Puget Sound to health. As noted in Section A2.2, the
Wilderness Act and the Wild and Scenic Rivers Act are two valuable tools to protect some of the
region’s most pristine and high quality lands and rivers. The 2008 version (updated May 27, 2009) of
the Action Agenda included support for Wilderness and Wild and Scenic designations. In the near
term action A.2.2 of the 2008 version, the Puget Sound Partnership committed to, “Advocate for
proposed Wilderness designations: a) support Alpine Lakes Wilderness addition and b) Pratt River
Wild and
Scenic designation.”
This near-term action was an important first step, and efforts to secure protections for lands near
the Alpine Lakes Wilderness and the Pratt River are ongoing. Therefore, we strongly support the
inclusion of this action in the updated Agenda. We also urge the Partnership to expand this action by
including the following protection priorities:
- Wild and Scenic designation of the Middle Fork Snoqualmie River;
- Wild and Scenic designation of Illabot Creek in the Skagit basin;
- Wilderness and Wild and Scenic designations for important rivers and lands on the Olympic
Peninsula; and
- Wild and Scenic designations in one of the region’s most important watersheds, the Nooksack
River basin.
A1.1 – NTA 1: PSP will convene an interagency workgroup by 2012 that, by 2013 will prepare regional
ecosystem protection standards with a decision-making framework.
The work prescribed in A1.1 adds additional layers of government oversight and bureaucracy
without addressing current activities in the regional ecosystems. While there may be gaps in the
ongoing activities, the first steps in developing a protection standard should include reviewing what
is and is not working within the existing structure.

A1.2 – NTA 2: …develop and distribute a set of local model planning land development and growth
policies….
Since the development of the Shoreline Management Act and the State’s Environmental Policy Act in
the 1970’s, the state has continually taken steps toward enhancing environmental protections. This
includes the local land use planning through the Growth Management Act, adoption of local
Comprehensive Plans, Critical Area Ordinances, rewrites of the stormwater manual, etc. The
implication under this near-term action is that something isn’t working today with new development
standards, rules or regulations. This is a false premise and we challenge the Partnership to first find
the gaps before developing new model plans.
In addition, the GMA, the SMA, and SEPA all explicitly recognize to need to balance the need to
protect the environment with our need to use natural resources and systems to provide those things
that are necessary for our society to continue to exist. The decisions that establish those balance
points under these laws are subject to procedural requirements
that ensure broad public participation in those decisions. The decisions are made by publicly-
A.1.1, NTA 2
The idea that the Partnership would direct Ecology and Commerce to develop local model planning
land development and growth policies as related to the Growth Management Act (GMA) and the
Shoreline Management Act (SMA) and other planning processes is disturbing. Conditions change
drastically from city to city, even within Puget Sound, and a one-size-fits-all approach is wrong. Local
governments and communities need to have flexibility to accommodate local needs. Both GMA and
SMA have been legislatively designed to be programs built from the ground up instead of the top
down. This NTA must be rejected. It assumes control that has not been granted legislatively and
ignores local land use control.

A.1.2, NTA 3
BIAW is supportive of encouraging local governments to remove impediments for developers to
incorporate processes that are consistent with recovering Puget Sound, such as Low Impact
Development (LID). Concern arises, however, when removal of the barriers turn into mandating
private action and land use. The Partnership should also evaluate disparities existing in ongoing
actions.

A.1.4, NTA 1:
BIAW opposes integration of a “cumulative affects assessment” into current land use programs. The
presumption of this NTA is that new development causes the greatest harm to Puget Sound, when in
A1.1 Identify and prioritize areas that should be protected or restored and those that are best
suitable for (low impact) development.

p. 34-35 The stream typing discussion states that only some local governments use DNR stream
classifications to regulate land uses near water bodies. This should be more accurately quantified, as
current Commerce estimates are that most local governments do this, though many may not include
the DNR-required protocol of field verification of mapped and designated streams. Commerce
includes recommended guidance for local governments in WAC 365-190-130 (4)(f) that suggests this
is a useful method to classify streams, which are usually locally designated as critical fish and wildlife
habitat conservation areas. Also, we suggest that DNR clarify the status of this Forest Practices rule,
regarding the use of modern stream typing based on fish suitability and presence, versus the older
(“interim”) scheme of Types 1 through 5 (-030 vs. -031.) Currently the older (“interim”) scheme (in
WAC 222-16-031) is still the adopted version under the Forest Practices Rules.

p. 36 The timing of the Salmon Recovery Council agreement on a set of actions should be clearly
stated, especially as it is proposed to be “folded into the Action Agenda.” Uncertain timing of key
actions can undermine selected strategies.

A1.1 NTA 1: PSP will convene an interagency workgroup by 2012 that, by 2013, will prepare regional
ecosystem protection standards with a decision-making framework.

This appears to be directed at achieving broad agreement on consistent standards that can be
adopted by local governments. It remains unclear how such an effort could succeed, if it consists
only of state and federal agencies. Even with the participation of local governments and Tribes, such
an undertaking would be time consuming and would ultimately rely on the existing legal framework
to impose these standards. It is not certain that this effort would result in meaningful changes on the
ground.

A1.1 NTA 2: By 2012, The Puget Sound Institute will work with Ecology, Commerce, WDFW and
other partners to develop a tool to improve and support spatial landscape data collection, sharing,
A.1.1
Comment: There should be a greater emphasis on the PHS and other sensitive wildlife areas
identified by WDFW. These areas would then need to have local protection or acquisition to
maintain the most sensitive fish and wildlife areas.
Recommended Edit: See specific instances listed elsewhere in WDFW comments where Priority
Habitat and Species information should be appropriately referenced.

Comment: WDFW PHS has identified important marine priorities based on spawning and bird habitat
among others. In addition Pacific Flyway and salmon recovery plans have priority areas and habitats
that have been specifically identified in Puget Sound.
Recommended Edit: See specific instances listed elsewhere in WDFW comments where Priority
Habitat and Species information should be appropriately referenced.

Comment: This section appears to be appropriately focused on issues primarily related to watershed
development – managing growth in upland areas. It does not explicitly address the issue of
nearshore protection and restoration referenced for this section in B1.1. For instance, WDFW work
to identify important areas of marine and nearshore biodiversity as part of PSBC, and the work of
PSNERP to identify locations for processed based restoration and protection don’t appear as specific
references.
Recommended Edit: It is more appropriate to address nearshore protection and restoration issues
under B1 than to attempt fitting them into this section.

Comment: The description of the Puget Sound Basin Characterization project is inaccurate and must
be rewritten.
Recommended Edit: Change 1st paragraph to read: The Puget Sound Basin Characterization’s (PSBC,
or the Characterization) assessment of water flow, water quality and fish and wildlife habitats is a
coarse-scale tool for identifying ecologically important areas. This assessment is a key step toward
determining which areas are appropriate places for low-impact development, and which places
should be protected from development. Applying the information in the Characterization should
A.1.1.2
Please add DNR to the list of partners.

A3.2
Please change the performance metric to read:
“Demonstration of pilot market transactions for delivery of watershed services from private
landowners will be implemented in Snohomish and Nisqually or equivalent watersheds by December
2012.”

A.3.3
Please change the performance metric to read:
“By Q3 2013 DNR will have developed, obtained authority for, and initiated a collaborative process.”

Page 37, Upland and Terrestrial
Please add the underlined to the last sentence under A.1.2, reflecting the need to integrate land use
planning and water quality in local land use planning and decision-making:
“This sub-strategy has the explicit purpose of incorporating relevant ecological, water quality,
sediment quality, planning and land development information into local decision-making processes.”

Please add SEPA under ongoing programs on page 37 as the third major statute governing planning
and land development in the Puget Sound region. Mitigation sequencing in particular is a critical tool
in SEPA that enables more complete information to be considered and better decisions for the
environment to be made.

Page 38, Upland and Terrestrial
Please add water quality standards to A.1.2.3.

Page 45, Upland and Terrestrial
Please add water quality to the first sentence of the third paragraph so that it reads:
“A functioning, resilient Puget Sound ecosystem includes landscapes that provide important habitat,
water quality, and hydrology functions….”
A1: Focus Development Away from Sensitive Areas
For Section A generally, sub-strategies 2.1, 5.1, 5.3, 5.5, 6.2, 6.3, 7.2 and 7.3 – There are a number of sub-strategies for which
the NEP Watershed Grant has identified pilot projects to fund. It might be useful to include NTAs for these strategies to the
effect: “Ecology and Commerce will fund and provide technical support for pilot projects at the local level that accomplish this
strategy.”
Page 34, “Ongoing Programs”, suggested technical changes: “The Puget Sound Basin Watershed Characterization’s (PSBWC,
or the Characterization) assessment of Water Flow, Water Quality and Biodiversity importance of Puget Sound Basin lands and
waters is an important primary tool used to identify ecologically sensitive areas. This assessment is a key step for identifying
which areas are appropriate targets for low-impact development, and those which should be protected from development
when used in conjunction with other watershed information and data can help identify which areas should be protected from
new development and those areas appropriate for low impact development.”
Page 34, “Ongoing Programs”, second paragraph, third sentence; suggested technical change: “The assessments cover the
entire contributing drainage area of Puget Sound and represent the physical, chemical, hydrologic, wildlife, freshwater and
nearshore habitat and human attributes of this landscape that support and interact with the structure and function of
ecosystems in Puget Sound.”
Page 34, “Ongoing Programs”, generally: Note: It may help to look at the Executive Summary for the latest Guidance
Document for the Characterization when editing this section. Here are some excepts: The Puget Sound Characterization is a
set of water and habitat assessments that compare areas within a watershed for restoration and protection value. It is a
coarse-scale decision-support tool that provides information for regional, county, and watershed-based planning. The
information it provides will allow local and regional governments, as well as NGOs, to base their decisions regarding land use
on a systematic analytic framework that prioritizes specific geographic areas on the landscape as focus areas for protection,
restoration, and conservation of our region’s natural resources, and that also identifies areas that are likely suitable for more
development. Application of this method should result in future land-use patterns that protect the health of Puget Sound’s
terrestrial and aquatic resources while also helping to direct limited financial resources to the highest priority areas for
restoration and protection. The assessments cover water resources (both water flow and water quality) and fish and wildlife
habitats (in terrestrial, freshwater, and marine nearshore areas) over the entire drainage area of Puget Sound. The
assessments provide a watershed-scale perspective on the relative importance of small watersheds (~ 1–10 square miles) for
the protection and restoration of water resources and habitats that is not generally provided by other available tools. Final
A1. Focus land development away from ecologically important and sensitive areas.
Recommendations:
Include how this relates to MSP:
Given the spatial nature of this action and sub strategies, this type of information would be useful for
MSP activities. Collecting information particularly in terrestrial lands bordering coastal waters
contributes to larger EBM model of coastal management and can contribute to MSP planning efforts.

The associated science research listed in the BSWP (p16) describe the collection of water flow
characteristics to ID the most important areas to protect. Since this tool is useful to MSP
practitioners, make sure they are aware of the development and utility of this tool.

Data collected in B1, NTA2 can also contribute to this overall action (A1).
It seems a number of the near term actions (NTAs) overlap strongly with the items on the Science
Plan. However, NTAs are not worded clearly enough to determine whether these are the same or
interdependent items. As the Science Plan exists as a separate document, some NTAs may be
duplicating Science Plan items. If they are interdependent, the timeline seems questionable. For
example:

A1.1 NTA2 (page 37) -- "By 2012, the PSI will work with …other partners to develop a tool to improve
and support spatial landscape data collection, sharing and analysis to improve the ability of agencies
to make land use decisions based on watershed assessments."

…seems very similar to the following Science Plan items (page 16-17)
"- Complete watershed assessment tools…
 - Develop decision support tools to assist in resolving ambiguities or conflicts…among the different
watershed characterization tools
 - Improve the assessment tools by incorporating additional characteristics of the ecosystem and
ecosystem services that are not in the initial tools
 - Incorporate social science research to …link restoration science to management decision-making"

The discussion about giving information and tools to local governments should reference our Green
Bylaw Toolkit to illustrate that many jurisdictions around the world are seeing value of having these
tools available for local governments.

We believe that it’s a good idea to coordinate funding programs (such as for acquisition of
conservation areas) so that they align with Sound-wide objectives. However, it would also be
beneficial to ensure that all existing and new conservation areas are mapped at a very fine scale. We
have done this for the conservation areas in BC and now share a single database with our
conservation partners. Having certainty over the boundaries helps with planning and reporting at
multiple scales.

Strategy A, Subtask 1.1, NTA#2 (Page 16) In the development of a tool for spatial landscape data
collection, sharing and analysis, consider extending the geographic scope of the project north of the
border to the Georgia Basin, particularly where transboundary patterns of land cover and uses may
be affecting transboundary water bodies, species and habitat. Currently, EPA and EC are looking to
collaborate on the use of comparable methods to generate high resolution land cover change data
using technology innovated by the WA Dept of Fish and Wildlife.

Strategy A, Subtask 3.2, NTA#1 (Page 17) To support the creation of a Comprehensive Conservation
and Ecosystem Service Market, consider linkages to the Canadian interdepartmental project known
Page 34. Ongoing programs- Watershed Characterizations and Stream Typing (A1.1). The Watershed Characterization project
was a high priority (and well funded) near-term action from the 2008 Action Agenda. The text on these pages should a)
reference that, b) indicate how many have been done, and c) give some information on how they are actually being used
(assuming that they are). Similarly for stream typing – what percentage of Puget Sound has been completed?
Page 36. A1.1 NTA1. Language for this near-term action is rather cryptic. An example of an ecosystem protection standard
from one of the listed frameworks should be given.
Page 37. A1.1 NTA2. Science need identified is quite a complex, time-consuming and expensive task as experienced by
PSNERP. Identifying the ingredients (necessary data layers), combining the right data into a coherent, logical and consistent
analysis e.g. creation of scoring criteria for conservation is considerably more difficult. Each of the existing tools should map
their coverage over the entire Puget Sound ecosystem and a decision support tool developed only for those areas left out of
either PSNERP, Salmon Recovery, PHS, etc.
Page 37. Ongoing programs – Planning (A1.2). It would be helpful to also include descriptions of efforts such as the Puget
Sound Regional Council’s work.
Page 39. Ongoing programs – Permitting (A1.4). It would be helpful to include a brief table that lists that existing permitting
programs that would be considered in this action, such as NPDES, 401/404, etc.
Page 39. A1.4 NTA1. A third party auditor such as OFM or the Partnership staff should be given this task rather than a line
natural resource agency with a regulatory or fiduciary mandate that includes a no net loss policy. Delegated programs such as
SMA and GMA will have to include a system of self-reporting followed by a sample check-up of representative jurisdictions by
OFM or the Partnership to ascertain level of compliance to the policy.
Page 42. Obtain Full or Partial Property Interests (A2.1). What constitutes a project being “referenced” in the Action Agenda?
Can the Action Agenda incorporate all projects on the Habitat Work Schedule by reference, for example, rather than having to
list a project within the Action Agenda itself? This would be preferable as the HWS is the agreed upon
system for storing proposed and active projects and would prevent funding from one of these accounts being withheld
because the project was conceived after the publishing of this version of the Action Agenda.
Page 43. A2.1 NTAs 5 and 6. Why is the Forterra project called out specifically? Is it because of the explicit direction to state
agencies? There are a number of qualified priority into the classification tools. There are vegetation and hydrologic models
A1.1 - It would be reasonable to plan to include CCacquisition projects identified in HWS, many of which may ultimately
that could be run with CC scenario outputs (e.g. on stream temperature). Several federal agencies are doing that currently.
Impact avoidance is critical to a no net loss of ecologically sensitive areas as restoration efforts are carried out in adjacent
compromised areas. Protected status will preserve ecologically sensitive habitats in a well functioning ecosystem. In carrying
out A1, to "Focus land development away from ecologically important and sensitive areas" the Partnership should engage the
collective expertise of State and federal agencies, tribes and NGOs. We support the use of the Washington State Department
of Ecology’s Watershed Characterization Tools, the Washington Department of Natural Resources’ Natural Heritage Program
(NHP; using NatureServe, State listed rare species and species of concern, historic and current prairie and oak woodland,
Natural Heritage Wetland, and other data bases and data layers they have developed as part their NHP), and Washington
Department of Fish and Wildlife Priority Habitats Data definitions, databases and data layers for State listed species or species
of concern.

-A1.1 “Identify and prioritize areas that should be protected or restored and those that are best suitedable for (low impact)
development.” As the draft Action Agenda acknowledges, the Puget Sound Basin Characterization is a decision-support tool
rather than decision-making tool. For this reason, it will be important to establish the criteria for identifying what those
agreed upon "ecological important and sensitive areas" are in order to focus these actions in the Agenda. The Action Agenda
should address who will be engaged and involved in developing the criteria and those “ecologically important and sensitive
areas.”

-A1.1 NTA 1 – PSP will convene an interagency workgroup by 2012 that, by 2013, will prepare regional ecosystem protection
standards with a decision making framework.” It is not clear what these standards would consist of in scope or effect or how
they would work with or be connected to relevant ongoing programs and activities. The generic reference to a supporting
decision making framework is not adequately described (e.g. Are these voluntary decisions? Would they work in concert with
other statutes or regulations? Who would be responsible for overseeing these standards?). If this NTA is pursued, the action
should be to scope and refine a proposal that could be then considered for adoption and implementation.

-A.1.4 NTA 1 – “[Who?] will convene a workgroup, by 2012, that will, by 2013, conduct a cumulative [e]affects assessment of
the ‘no net loss policy’ in producing net gain toward the recovery targets and articulate how cumulative effects assessment
could be integrated into existing programs.” It is not clear what ‘no net loss policy’ is being referred to (i.e. the federal no net
loss policy under the Clean Water Act section 404, a State policy directed at Critical Areas, wetlands or shoreline
management, Action Agenda recovery targets or is this intended to provide a benchmark objective to local resource or land
management programs?) Any cumulative effects assessment would either need to be directed at a specific category of
resource or at a specific program with a specific no net loss objective. A generic cumulative effects assessment that is not
Thank you for recognizing the Kitsap Forest and Bay Project as a regional near-term priority. We have
an extraordinary opportunity to preserve 7,000 acres of forested uplands, nearshore, and tidelands
surrounding Port Gamble Bay in North Kitsap County. The conservation of this area will greatly
contribute to achieving multiple Puget Sound clean up targets and spans two Action Areas. Please
maintain the following priorities in the Action Agenda as currently written:

A2.1 NTA 5: Forterra, working on behalf of Kitsap County, the Port Gamble S’Klallam Tribe and the
Suquamish Tribe, will coordinate funding and agency participation to secure the conservation of
~7,000 acres of land near Port Gamble, including ~2 miles of shoreline, within the next 30 months.
Performance measure: acres and miles of shoreline protected.

A2.1 NTA 6: PSP, working with Forterra, Kitsap County, the Port Gamble S’Klallam Tribe and the
Suquamish Tribe will convene the State agencies, federal agencies and federal delegation to seek
their engagement in leveraging available resources – from funding to programmatic involvement, as
possible – to conserve and restore the ~7,000 property near Port Gamble.
Performance measure: acres and miles of shoreline protected.

(additional comment) - Port Gamble Bay is part of an interconnected ecological system that supports
species in Hood Canal, Admiralty Inlet, and Central Puget Sound. The preservation of these lands are
applicable to Sound-wide strategies A-Protect and Restore Terrestrial and Freshwater Ecosystems
and B-Protect and Restore Marine and Marine Nearshore Ecosystems. Specifically, this project
directly addresses 19 of the 21 Ecosystem Recovery Targets, including:
- Shellfish beds: The bay is currently open to harvestable shellfish beds which are critical to the
livelihood of the Port Gamble S’Klallam Tribe.
- Wild Chinook salmon: Estuarine habitat in the bay provides a place for juvenile Chinook salmon and
Great Peninsula Conservancy appreciates this opportunity to comment on the Puget Sound
Partnership’s draft Action Agenda update. Our comments will focus on forest conservation,
specifically models for working comprehensively at a landscape and watershed scale within our land
trust’s geography.
Upland and Terrestrial Considerations for Forest Conservation
Great Peninsula Conservancy would like to call out the importance of upland forests to groundwater
recharge and downstream water quality. While important across all regions, this is especially critical
for the Kitsap Peninsula, and other areas such as Whidbey, Camano and San Juan Islands, where
precipitation is the sole source for our potable water supply and stream flow. We support PSP’s
target of reducing land development pressure based on loss of vegetative cover (page 32).
Action Areas- Feedback on Forest Conservation
Great Peninsula Conservancy supports the inclusion of the Kitsap Forest & Bay Project (Port Gamble
conservation) on the Puget Sound Partnership’s regional Near Term Action list (A2.1 NTA 5 and 6,
page 483), as well as on the Near Term Action lists for both North Central/West Sound and Hood
Canal action areas. This project proposes to conserve nearly 7000 acres of forest and 1.8 miles of
shoreline on Port Gamble Bay – all of it currently under single ownership with a willing seller. The
project addresses most (19 of 21) of PSP Action Agenda targets and encompasses two action areas
(North Central and Hood Canal). Conservation actions with this high level of impact and urgency –
the land is now zoned into 20-acre parcels and slated for development/sale beginning in 2013/2014
– are rare.
Support of Forest Conservation Initiatives Demonstrating Landscape and Watershed Scale
Approaches
Great Peninsula Conservancy supports landscape- and watershed-scale forest conservation. On page
308, the Hood Canal Action Agenda identifies two groups of forest initiatives and differentiates them
From 2007 through last year’s passage of ESHB 1886 we served as Coordinators for our respective
caucus’ negotiating an agreement through the Ruckelshaus Center. As you know, our negotiations
resulted in the establishment of the Voluntary Stewardship Program that intends to assure the
viability of agriculture while protecting critical areas as defined by RCW 36.70A.030 (5).
These four Puget Sound counties adopted resolutions/ordinances to opt into VSP: Thurston, Mason,
San Juan, and Skagit.
In our review, there are some 30 Near Term Actions that are either directly or tangentially related to
the implementation of the Voluntary Stewardship Program. Thus, our request that a specific Near
Term Action be more clearly stated as follows:
“Support implementation, funding, and assistance to the Washington State Conservation
Commission and those Counties participating in the Voluntary Stewardship Program”.
• Clearly link state standards for local plans and regulations with recovery targets: The Action Agenda
recognizes the importance of appropriately protective local land use plans, regulations and policies.
Many of the NTAs associated with this, such as those under strategy A.1.2., call for the creation of
model ordinances, identification of barriers to implementation, or provision of technical information.
While these actions are helpful, we believe these may be insufficient to bring about changes that are
needed sound-wide. There should be more emphasis on clearly aligning state standards for review
and approval of local Shoreline Master Programs (SMP), local Flood Hazard Plans, stormwater
programs, and land use plans with actions needed to achieve Puget Sound recovery targets. For
example, SMP guidelines should clearly reference the recovery target for shoreline armoring, and
outline local regulatory and programmatic actions that can be taken to achieve that target.
Determining the appropriate mix of regulations, restoration, and protection actions is site-specific,
but the outcome must be sufficient to meet recovery targets.
• Strategy A1.4 should be clarified to ensure that the term “streamlining” is not interpreted to be
advocating the elimination of regulations.
• The assumption under NTA 1 and 2 under A1.2 is that with better information and model
ordinances, local governments will adopt appropriate policies and regulations to protect Puget
Sound. What will compel local governments to adopt these model ordinances?
Reliance on local governments is crucial for the success of a healthy Puget Sound. In reviewing the
targets and the near term actions, especially those related to land use, the implication is clear that
local governments are a key resource in improving the Sound’s health. Critical issues exist:
a. While well intended, is the development of model ordinances realistically worth the cost?
Adoption is nearly always a local political process which requires significant public participation per
the Growth Management Act and Shoreline Management Act, among several other laws. And, if
adopted, is the jurisdiction free from appeals of the “model ordinance” under current state laws? If
not, is the state or Puget Sound Partnership willing to take on the appeals process?
b. Stream lining the permits system is always a politically endearing idea, however the proposed
Near Term Action (1.4) does not illustrate how it will, in fact, streamline the permitting system. If
there is a desire to streamline permitting processes, look at the implementing system. For example, a
shoreline permit for a dock requires local approval first, and then the state and federal government
may issue a denial. Why not make the highest approving level the agency, in this case the Corps,
issue a single permit?
c. The provision of watershed planning tools is commendable. Many jurisdictions lack the ability to
model the impacts of development, even the best development, on a watershed basis. This modeling
Strategy A.1.2, NTA 2:
We are very concerned about the notion that Ecology and Commerce would develop a set of local
model planning land development and growth policies related to the Growth
Management Act (“GMA”), Shoreline Management Act (“SMA”) and other statutes and planning
processes. While I understand the desire to create some consistency across jurisdictions, the reality
is that conditions vary from city to city and across the Puget Sound region. We believe that local
governments should maintain their ability to implement these laws in a way that is protective of
Puget Sound, but also gives them the flexibility to address local needs. We do not agree that a “one-
size-fits-all” model regulation or policy approach to land use and growth policies is the answer, and
GMA and SMA were legislated based on a “bottom up,” not a “top down” land use policy philosophy.
Moreover, this proposed action pre-supposes that current regulations, many of which are
continually being updated, are not working. This NTA must be rejected.
Strategy A.1.4, NTA 1:
We do not agree that a “cumulative affects assessment” should be integrated into existing land use
programs, because this NTA assumes that new development poses the greatest threat to the health
of Puget Sound. We strongly disagree. The Partnership should focus most of its attention on the
existing built environment, especially all development that
was built prior to roughly 1990, before today’s regulatory regime for growth management and
stormwater controls were put in place.
However, if the Partnership does adopt this NTA, then we believe it must also include a cumulative
Watershed Sustainability: If watershed water quality cannot be improved to reduce pollutants so
pre-spawn mortality is reduced, because they are too urban – then we should limit restoration
funding to these areas and apply it to where runs can be sustained and improved.

A 1.1/1: How will the standards be developed and based on what science? Will the state legislature
adopt the standards such that local jurisdictions if using do not have to contend with local property
rights groups, environmental groups, etc. in using the standards? GMA states that local jurisdictions
are to use best available science in developing their Critical Area Ordinances. Same applies to
Shoreline Master Plan updates. Yet, the constant challenges occur at the local level which causes
local planners to spend an inordinate amount of time “proving,” debating, getting political buy-in,
etc. to enact the most basic of protection standards.
A1.2/2: Local jurisdictions planning under GMA must develop and ratify countywide planning
policies. In the Puget Sound, King, Kitsap, Pierce and Snohomish must also ensure they CPPs are
consistent with Puget Sound Regional Council’s Multicounty Planning Policies. Achieving agreement
is often difficult given the desire for “local” control. Now another set of policies are to be given to
jurisdictions to consider and/or incorporate. By the time these policies are developed and pushed
down to local jurisdictions, will they be advisory? If so and a jurisdiction chooses to use them, will
they appealable to the Growth Management Hearings board?
A1.2/3: Local jurisdictions need to participate in this near term action as barriers vary from
jurisdiction to jurisdiction and may primarily rest on the local constituents, the level of their
interest/financial support for or against a position, model code, etc. A second barrier is often the lack
of staffing at local level to move code through the public process. A concern is the publication of the
model policies and regulations and then expectations they will immediately produce the desired
results. What is the expected time period for implementation and actually achieving something
additional activities that are easily tracked for Parks and may be addressed by existing NTAs are:

•Land acquisition – may be addressed in the Public Access section although a draft of this section
does not seem to be available, in the old action agenda it was addressed under NTA A.2N1.2
p.38 - We support the near-term actions that enable local governments to update land development
and growth policies consistent with protection and recovery targets, particularly the protection of
shoreline areas from activities that may harm nearshore habitats. We urge Ecology and Commerce
to provide increased oversight and direction to local areas for these actions.

We appreciate the inclusion of A2.1 Near-Term Action 5, which calls for Forterra to coordinate the
permanent protection of lands near Port Gamble Bay, including the shoreline, within the next 30
months. The local Shoreline Master Plan Update should be consistent with both this A2.1 – 5 Near-
Term Action, as well the MTCA cleanup actions underway in Port Gamble Bay.

Shoreline Master Plan designations should reinforce restoration and protection plans, and not
detract from near term progress and long-term protection. Shoreline designation planning for Port
Gamble Bay, now underway, is one example of potentially inconsistent land use actions at local and
state levels.

Suggested language under A1.2 NTA: Where local planning is inconsistent with Puget Sound
recovery strategies, and/or the Action Agenda, Ecology or Commerce will provide oversight and
direction to local governments as needed.

The strategy described in NTA A.1.1 is to identify and prioritize areas that should be protected or
restored and those that are best suitable for low-impact development. Renton supports this NTA
provided it is developed in the context of existing land use requirements (e.g., SMP, CAO). For
example, this might affect the ecological restoration requirements for SMP updates. Will local
governments be expected to incorporate these standards in order to be viewed as participating in
recovery? Local governments will need to participate in this NTA to ensure standards are
implementable and to avoid unreasonable harm to economic growth. The ecosystem protection
standards need to be developed with input from all interest groups (environmental, local
government, businesses, and citizens).

NTA A.1.2 would provide guidance through model ordinances for local plans, regulations and policies
to be consistent with protection and recovery targets for Puget Sound. And, NTA A.1.3 would
improve local governments’ ability to implement, monitor and enforce plans, regulations and
permits that are consistent with protection and recovery targets for Puget Sound. It is unclear how
the required balancing of different GMA goals and requirements (population growth, buildable
lands, affordable housing) will be factored into these NTAs. It would be of great assistance if this
NTA focused on finding examples of good things already being done, and provided those examples as
a resource of existing tools.
A1.1: The progress of the stream typing project and the Puget Sound Basin Characterization should
be mentioned in this section. (p. 35)
A1.3, NTA-1: The responsibility of promoting broad partner discussion of ways to promote state
financial support for local governments for GMA comprehensive plan implementation, enforcement,
management, training, and education should be granted to a third-party, not a government
department. Third-parties, such as NGOs or consulting agencies, could more efficiently facilitate a
dialogue between state and local governments to address comprehensive plans regarding GMA than
the state government. Where there are immediate actions identified, it could be more effective to
allow third-party agencies to through contract or grant programs. (p. 39)
A.2, Target View: It is unclear how this fits in with the strategies listed in section A. The organization
and placement of the target view should be changed. (p. 45)
A.4, Target View: Again, it is unclear how this target view relates to the strategies listed in this
section. Perhaps, the target views should all be grouped together in their own section. (p. 58)

Potential Legislative Action
Comment: The Partnership should look at these and other funding mechanisms/allocation formulas
for opportunities to support and encourage density as one of the few effective ways to address
increasing population growth and maintain open space and functionality.


Land Acquisition and Easements. The terms “protect” and “protection” are employed throughout
the Action Agenda, but it is difficult to determine when these terms are being applied to legal
regulations, and when they are being applied to conservation land acquisitions and easements.
Protecting lands through conservation land acquisitions and easements is critical to salmon recovery
in the Puget Sound given the large habitat losses that have occurred due to historic development,
and due to the increasing pressure on remaining habitats resulting from an expanding human
population in the region. It is important to make this distinction because land acquisitions and
easements provide a high level of certainty in protecting the best remaining habitats, which is
important to consider when land-use regulation and political administration changes occur much
more rapidly the 50-year plus time frame needed to restore ecological processes and recover
sensitive species populations.

Comments on Selected Strategies
A1 Focus Land Development Away from Ecologically Important and Sensitive Areas
A1.1 Identify and prioritize areas that should be protected or restored and those that are best
suitable for (low impact) development
Comment: From the description, it sounds like the tool for identifying and prioritizing is the state
watershed characterization. However, the Action Agenda should recognize local characterizations,
particularly since we’ve learned that the state characterization resolution is not fine enough to
capture more urban watersheds. Seattle has detailed watershed analyses for its 5 major urban
creeks, plus the shoreline characterization, and GIS analyses; priority projects are selected and
decisions made about acquisition, restoration and low impact development (green stormwater
infrastructure) using this information. Key projects that are important for salmon are on the 3 and
10 year lists for the salmon recovery plans.

A1.3 Improve local governments’ ability and willingness to implement, monitor and enforce plans,
regulations and permits that are consistent with protection and recovery targets for Puget Sound
Comment: Lack of funding is a major obstacle even in larger jurisdictions whose planning
departments depend upon fees and general funds for their budgets, which have been significantly
cut the last few years.
A1 Focus Land Development Away from Ecologically Important and Sensitive Areas
General Comment: Again, the Partnership should look for ways we incentivize density as way to
address pollution reduction and open space protection

A1.1 Identify and prioritize areas that should be protected or restored and those that are best
suitable for (low impact) development
Comment: This section needs to specifically address the implementation of the Chinook recovery
plans that were developed for all of the PS WRIAs.
A1. Focus land development away from ecologically important and sensitive areas.

The Puget Sound Characterization is intended to identify areas where development might be appropriate, and areas that should be preserved and
restored from the impacts of development. Though this may be an admirable goal, we have some reservations about how this will be
implemented at the local level, and particularly how much influence the Characterization will have. Prior to the finalization of the plan, we
request that representatives from the Washington State Department of Ecology, the Washington Department of Fish and Wildlife, or the Puget
Sound Partnership who are fluent and extensively knowledgeable on the implications of the document, present the local results to the tribes and
the local watershed groups for comment.

A1.4 Strengthen and streamline existing local, state, federal permitting programs.

The Stillaguamish Tribe encourages the Puget Sound Partnership to act as a third party facilitator to evaluate local, state and federal permits
required for restoration projects and assist with streamlining that effort. Though the Partnership is a state agency, it has no regulatory influence
in and of itself, and so it is the perfect conduit for a thorough analysis of permitting procedures.

A2.1 Obtain full or partial property interests for lands at risk of conversion or impacts from human activities.

Protecting lands prior to degradation is ecologically and financially preferable to restoring already degraded lands. Also restoration of private
land is often unrealistic given landowner constraints and future uncertainties of ownership. In order to ensure permanent protection, ecologically
sensitive land must be obtained by a public entity, an environmental non-profit of high reputation or a tribe. Recently, attempts by the
Stillaguamish Tribe to purchase ecologically important properties have been frustrated by several political barriers.

The first is an opinion by some local governments that environmental regulations are currently ensuring no further degradation to ecologically
sensitive lands, and therefore permanent protection through acquisition is unnecessary. However, there is no accountability, or requirement to
prove these regulations are, in fact, effective. Based on our observations in the Stillaguamish, habitat degradation is ongoing (both permitted and
unpermitted), despite these regulations. The burden of proof should lay on the shoulders of the regulatory jurisdictions to definitively prove that
their regulations are not resulting in continued habitat degradation. We request that PSP work with the Governor to enact legislation that
requires periodic evaluation of the effectiveness of regulations and that these findings be distributed widely to the public. In the meanwhile, the
Natural Resources Department of the Stillaguamish Tribe is planning a study over the next several years to determine if local environmental
p.39 - A1.4 NTA 1
Suggestion: The Strait ERN supported 2009 EPA funded Enhanced Shoreline Protection (No Net Loss)
project sponsored by Clallam and Jefferson counties and Ecology may help to inform the direction of
this NTA.
The upland and terrestrial chapter highlights both areas of common ground and areas of differing
priorities and realities. For example on pg 30, The Wild and Scenic Rivers Act designation is described
as a tool to protect key ecological processes. The Tribe does not agree that this designation provides
real protection of the aquatic resources. Emergency permits to protect capital infrastructure have
been used to rip rap stream banks in the Skagit, yet mitigation plans to address these impacts have
to complete the permit process under Wild and Scenic Corridor Act. Plans to mitigate these impacts
have to overcome significant scrutiny and costs under the review of the Wild and Scenic Rivers Act
requirements.

The Land Development target 1: "Basin wide, by 2020, loss of vegetation cover on indicator land base
over a 5-year period does not exceed .15 percent of the 2011 baseline land area." Pg 32. It appears
that a no net loss of key ecologically sensitive lands should be the target put forth in this ambitious
planning. Salmon stocks are in peril; habitat fragmentation, habitat productivity, and pollution are
the cause so why aspire for continued degradation of key landscape features? The current status and
trajectory of key ecological process loss, has resulted in multiple ESA listings across the basin. The
target utilizes the Puget Sound Basin Characterization (PSBC) assessment to identify key lands for
Prairie and Oak Woodland Habitats
In the Action Agenda it is noted that prairie habitats have been reduced greatly from historic levels.
We note that prairies and oak woodlands contribute to the ecological diversity of the Puget Sound
basin and the Pacific Northwest. Prairies are mentioned only 3 times in the document and oak
woodlands do not appear to be mentioned at all. Therefore, we recommend incorporating more
information on prairies and oak woodlands into the revised Action Agenda to emphasize the
importance of these habitats to maintaining overall species diversity. Please feel free to use the
language below should you wish.

The Puget Trough physiographic province is one of the most ecologically diverse and productive
ecosystems in the western United States. The Puget Trough was formed by glaciers during the last ice
age, about 15,000 years ago. Prairies in this region are underlain with outwash from the retreating
glaciers. The gravelly, well drained soils were a major factor in creating prairies and oak woodlands.
The native prairie ecosystem is composed upland prairies, wet prairies, oak savanna and woodlands,
wetlands and associated streams throughout western Washington.
Upland prairie is important habitat for a variety of unique plant and animal species. A number of
species are dependent upon this habitat, including the federally listed golden paintbrush (Castilleja
levisecta). Other candidates and species of concern find optimum habitats on prairies in the Puget
Sound region, including several subspecies of Mazama pocket gopher (Thomomys mazama), streaked
horned lark (Eremophila alpestris strigata), butterflies including Mardon skipper (Polites mardon),
Page 52, “UW Sea Grant” should be omitted as this is one area of outreach where we do not have
activity.


A1.1 Identify and prioritize areas that should be protected or restored and those that are best
suitable for (low impact) development.
This discussion of this sub-strategy includes a description of water-typing and its role in Forest
Practices Act applications but then goes on to state that “[w]hile some local government entities
(LGE) also use these maps for land use regulation, DNR does not require their use nor do they
maintain the maps specifically for LGEs.” That is not an incorrect statement, but it is hardly a
complete one. The Growth Management Act requires local governments to protect Washington’s
watersheds from adverse impacts associated with development, thus placing a high degree of
responsibility for ecosystem protection onto those local governments. Generally, municipal planning
and the application of conservation regulations like streamside buffers depend on the accuracy of
regulatory water type maps, which is the standard state process by which streams are identified and
classified. This basic mapping inventory is fundamental to conserving the health of Washington’s
watersheds and the marine environments they feed. Unfortunately, the current water type
regulatory maps maintained by DNR either underestimate the actual miles of fish-bearing waters (in
There is 50 percent or more) and funding of CREP, an existing stream. However, references the
cases by a need for expansion or even fail to identifyas the AA mentions. For the most part, it isto CREP
should also recognize the efforts of landowners’ voluntary stewardship. These issues will not be
solved through the efforts of agencies alone—it is important to stress the necessity of public-private
cooperation. It would also be beneficial if there were technical and financial assistance for
commercial and residential restoration of existing development (soil improvements, native plants,
etc.).

WRIA 16 strongly supports the concepts in Section A2 to Permanently Protect the Intact Areas of the
Puget Sound Ecosystem that still function well, and would like to see these concepts even more
strongly emphasized throughout the Action Agenda. It is more effective to protect ecosystems than
to correct them after they have been harmed. A good example of this type of effort is the Great
Peninsula Forest and Bay project.
Strategy A, subtask 3.1
Create and offer an expanded, integrated suite of incentives and market-based programs that make
voluntary stewardship and conservation of private forest and agricultural lands practical and
economically rewarding
NTA #1
By 2012, the Conservation Commission will work to enhance use of all USDA conservation and
habitat restoration program funding, i.e., CREP and EQUIP, which are currently underused by and
not tailored for western Washington growers.

WSCC Comment: Support

Strategy A, subtask 3.3
Develop a comprehensive strategy for retaining economically viable and long-term successful,
working agricultural and forest lands through a collaborative process.
NTA #2
PSP, in collaboration with Agriculture, Ecology, and the Conservation Commission, will convene a
series of workshops to engage agricultural stakeholders to identify needs for maintaining the health
of the industry, and identify key areas where the agricultural industry can assist in the protection and
restoration of Puget Sound

Section A3.3 calls for the development of “a comprehensive strategy for retaining economically
viable and long-term successful working agricultural and forest lands through a collaborative
process.” It is therefore critical to implement NTA A3.3 NTA 2:

PSP, in collaboration with Agriculture, Ecology, and the Conservation Commission, will convene a
series of workshops to engage agricultural stakeholders to identify needs for maintaining the health
of the industry, and identify key areas where the agricultural industry can assist in the protection and
restoration of Puget Sound.

In order to successfully achieve the recovery of Puget Sound by 2020 all parties must be engaged and
represented, otherwise we run the risk of the Action Agenda being viewed as a top-down regulatory
document as opposed to the collaborative effort the Partnership represents.

Throughout the document, there are references to preservation of farmland and forestland, but only
one apparent reference to maintaining and enhancing the viability of natural resource industries like
agriculture and forestry. Maintaining and enhancing these industries – major portions of the
Washington economy – is one of the goals of the Growth Management Act. It should also be a
priority for the Puget Sound Partnership.
The stated near-term action is for Ecology, Agriculture and the Conservation Commission to convene
a series of workshop to engage agricultural stakeholders to identify needs for maintaining the health
of the industry and to identify key areas where the agricultural industry can assist in the protection
and restoration of Puget Sound.
It is critical to recognize that health of the agricultural industry must involve less regulatory
interference, ending government policies that take agricultural land out of production, and an iron-
clad commitment that governmental action (regulations, eminent domain, agency land purchases,
etc.) will no longer reduce the acreage or productive capacity of our farms. There is ample reference
in the document to the preservation of ecologically valuable lands, but no apparent reference to the
current ecological benefits provided by farms. Floodwater dispersal, fish & wildlife habitat, open
space, view sheds, water filtration, and many more benefits are provided by our farms.
Surely, there should be some recognition in the plans of the Puget Sound Partnership that farms are
• It seems as though task 1.2, "developing model land-use policies and goals" should be linked with
task 6.3, "restoration in urban areas balancing urban in-fill." Task 6.3 currently does not have any
identified near term actions.
• Task 1.3 - It is not that the local governments are not "willing" to implement actions. This language
is biased and does not take into account conflicting mandates, limited capacity, and other demands
which may make implementation more challenging.
Must have ship traffic cruats over the years
Balast water management: invasive species prevention eradication
B8.1 NTA 2: (Page 109) Priority: MODERATE

The Invasive Species Council, in collaboration with PSP, will begin developing an early detection and
monitoring program plan for priority invasive species in Puget Sound. The Council and PSP will
coordinate the plan and implementation efforts with the Puget Sound Coordinated Ecosystem
Monitoring and Assessment Program.

Rationale
Same as All.1 NTA 2. Incorrect direction on PSP role for NTA. PSP is a member of WISC and does not
have any other specific responsibility as an agency for this NTA. The key concern is captured in the
last sentence on working with the PSCEMAP (Kevin Anderson, PSP - personal communication).

B8.1 NTA 3: (Page 161) Priority: HIGH

DFW will evaluate options for managing invasive species transported on and in the hulls of
recreational watercraft and commercial ships.

Performance measure: Complete literature survey and a management plan with draft
recommendations by June 30, 2015

Rationale
The NTA needs to be broadened to include evaluation of recreational watercraft hull fouling as
recognized at the most recent meeting of the Puget Sound Marine and Nearshore Grant Program
work group. The performance measure has always been discussed as a management plan - not a
Page 160
Please note in Ongoing Programs that DNR has an active aquatic vegetation invasive species
program. Also, eelgrass is one word, not two.

Page 160. Marine invasive species – ongoing programs (B8). The list of ongoing programs should
include the national NPDES permit for ballast water dishcharges and the current effort to improve
this.
B8.1 (page 161) “Prevent and respond to the introduction of marine invasive species” – Some of
these NTAs are the same as those in A11.1, so could potentially be consolidated if the entities that
deal with marine/estuarine invasive species are not separate from those that deal with freshwater
invasive species
B8.1: In addition to WDFW evaluating the effectiveness of open sea exchange and treatment in
meeting state ballast water standards, we request that WDFW increase field inspections of vessels to
better enforce state ballast water standards. (p. 161)
In B7.2 Implement existing marine and nearshore species recovery plans in a coordinated Way. This
section lists plans for sea otters, Southern Resident killer whales and rockfish, but does not include
the salmon recovery plan (although there is an empty inset box for salmon recovery plan priorities).
We support the Partnership’s recommendation is to identify overlapping actions within these plans
and eliminate redundancies. This approach provides an effective method for prioritizing actions that
benefit multiple species and support ecosystem recovery.

Near-Term Action B7.2 NTA1 is limited to state agencies prioritizing implementation of "restoration
projects" within existing species recovery plans. There are many actions in recovery plans beyond
restoration that are carried out by responsible parties other than states. This action could be broader
and include implementation of all types of actions in the recovery plans.

This section does not mention ongoing programs. We recommend the Partnership include ongoing
recovery implementation for Southern Resident killer whales and reference the 2011 5-year review
which describes ongoing actions and makes recommendations for future actions.
http://www.nwr.noaa.gov/Marine-Mammals/Whales-Dolphins-Porpoise/Killer-Whales/ESA-
Status/KW-ESA-5-yr.cfm
More information about ongoing programs for killer whale recovery complements the Orca target
B1.1, NTA 2:
Marine spatial planning should not supersede local control over land use decisions. This suggested
action should be eliminated.

B2.1-6, All NTAs:
BIAW is concerned with the PSP usurping local control and relying on non-existent science or fear of
future possible action as reasons to stop shoreline development. The cost to local governments that
will have to pay for the monitoring, lawsuits, and staffing of additional review requirements need to
be considered. Managing shoreline development is best left to the care of the local community, as
the Sound’s shorelines all have different needs. This is already done through the regular Shoreline
Management Act’s update process, which is reviewed and approved by the Department of Ecology.
These NTAs create redundant regulatory requirements in the permitting processes, and add to the
cost and length of the homebuilding process.

B3.2, NTA 1 and 2:
BIAW appreciates the Partnership’s attempts to use incentives for shoreline restoration and
welcomes more incentive-based actions to encourage for homeowners and developers to take the
lead on retrofits or building practices that serve to restore the Sound instead of mandates. These
specific NTAs appear to be reasonable assuming there is funding available for a low interest loan
Prevention of Harm: Enforce Laws
SMA: protect marine shorelines of statewide significance for long-term public benefit. Hold high
standard

Public Trust Doctrine means our right to clean water & fish in the water

Limit new docks

No Desalination of Seawater (a public resource) and turning it into a private commodity which allows
more growth along shorelines

Enforce strict building codes along shorelines

No mitigation banking for riparian habitat. No altering wetlands or riparian areas. Keep all natural
functions intact and on-site.

Cherry Point Herring = salvation

No Coal Port – support goals of Cherry Point Aquatic Reserve

Decrease train traffic on track liners within the shorelines

Actions: Enforce existing laws to protect, preserve, enhance out shorelines
Strategy B –
Why doesn't the WDFW HPA defer to current guidance and US Army Corp permit process, which has
been reviewed for compliance with the Endangered Species Act for Chinook and Bull Trout? Rather
than layering state and federal permit processes, this seems like an opportunity to streamline the
permit process.
p.120 Recommend the following edit: “GMA and SMA direct local jurisdictions to plan for growth
and development while ensuring the ongoing functioning of the ecosystems supported by critical
areas (wetlands, streams, slopes, etc.) or of no net loss of shoreline ecosystem functions and
processes.” It is important to note that the GMA definition of critical areas includes their associated
ecosystems.

p. 131 The existence of many miles of riprapped shoreline railroad lines is not even mentioned in this
discussion of shoreline armoring, which is a big information gap that should be filled. Even if
changing this situation is considered unlikely, keeping the current reality in front of the public and
decision-makers is very important.
General
Comment: There is nothing in the strategies about developing new projects to address known problems that we are unable to address because of social constraints. This
should be one of the highest priorities if we truly want to restore PS.
Recommended Edit: Consider how to get through impasse limiting development and implementation of solutions to known problems

B.1
Comment: The wording of this strategy is confusing and unclear. How do population and economic growth catalyze existing efforts for protection and restoration? What
connection is being drawn between these two things?
Recommended Edit: Reword strategy to deliver a clear message about the connections among these things.

Comment: "establish protection/restoration priorities" is vague and there are lots of priorities out there.
Recommended Edit: Clarify types of restoration and protection strategies needed.

B.1.1
Comment: B1.1. Background: I think that the opening paragraph for the B1.1. Strategy mostly hits the mark. That is, Marine and Nearshore NTA’s need to be predicated
upon general agreement around restoration and protection priorities. Recognizing that not all priorities identified by PSNERP, Salmon Recovery, local jurisdictions, etc.
overlap completely, at least recognizing areas of overlapping priorities can serve to collaboration and shared efforts.Unfortunately, I think that this important first
principle identified by the Interdisciplinary team (IDT) got lost in this review draft version.
Recommended Edit: Insert "new" NTA based on previous work of IDT: B1.1.1 Document priority areas for protection, restoration, enhancement, and managed growth for
nearshore and marine ecosystems. The process will integrate and reconcile priorities for process-based restoration and protection with those areas important to salmon
recovery, shellfish, and other natural resources. This list of sites will augment watershed restoration and protection priorities identified through Watershed
Characterization (A1.1) and used to further support local planning efforts (A1.2).Performance Metrics: Puget Sound Partnership convenes task force to integrate priorities
by July 2012. Maps or other documents identifying science-based priorities for protection, restoration, enhancement, and managed growth are completed for Leadership
Council review by December 2013.

Comment: Shoreline habitats assessment of the Puget Sound Basin Characterization project not listed.
Recommended Edit: Update text.

B.1.1.1-2
Comment: If the recommendation to add “the old” NTA 1 back into this section is NOT followed (see the comment beginning "B1.1. Background..." above), then these
two NTA’s dealing w/ MPA’s and MSP really don’t follow strategy B1.1. Thus, B.1.1. would need to be rewritten to focus specifically on marine protection, dropping all of
the background on shoreline planning and establishing regional nearshore priorities.
Recommended Edit: Insert "new" NTA based on previous work of ITR per previous comment

B.1.2
Comment: Section weak-- on-going program is an example of activities under this section but fall short of comprehensively addressing project evaluation in a
comprehensive way that can inform Puget Sound recovery- Can PSP and science panel take?
Recommended Edit: A NTA could be to identify an entity or mechanism for advancing this NTA. Otherwise, it is not that useful as is.

Comment: The Puget Sound Coordinated Ecosystem Monitoring & Assessment Program recently approved formation of a Nearshore Workgroup.
Recommended Edit: Develop new NTA to Task Workgroup with developing a strategy to integrate status and trends monitoring with restoration project monitoring
activities.

*See DNR spreadsheet for additional 2 pages of Marine/Nearshore comments
B.1.1.1
Please add DNR as a secondary owner. Please explain how this NTA relates to the statutory requirement that
PSP “….integrate marine spatial information and planning provisions into the action agenda….” (RCW.43.372.030
(2)(2).
Please change the NTA to read:
PSP, working closely with DNR, DFW and other partners, will develop a work plan for implementing a network
of marine protected areas in Puget Sound.

B.1.1.2
Please explain how this NTA is responsive to legislative direction to PSP in RCW.43.372.030(2)(2) to “….integrate
marine spatial information and planning provisions into the action agenda….”

Page 112, Marine and Nearshore
Please add the following targets to the list of those more related to marine and nearshore protection and
restoration:
swimming beaches; shellfish beds; Chinook salmon; Orcas; land cover and land development; floodplains;
marine water quality; marine sediment quality; toxics in fish

Page 114
Please add eelgrass to the list of targets on this page.

Page 116
Please add "DNR's Aquatic Landscape Prioritization" after "watershed characterization" in the last sentence on
this page.

Page 118
Marine Recovery Councils are misnamed. They are Marine Resource Committees.

Page 123
B.2.1.1 sets out a goal to permanently protect 10% of bluff-backed beaches with high sediment supply potential.
It is puzzling that this is such a low goal. It would seem that the goal ought to be to protect all of these critically
important areas.

B.2.1.2 should not emphasize the SMP no net loss requirement, as this will not lead to recovery, but should
B4: Protect Working Waterfronts
Technical correction on page 142; paragraph 1, 3rd sentence. Suggested changes: “Marine sediment
quality targets state that by 2020 all Puget Sound regions and bays shall achieve specific chemistry
measures set in the marine chemical criteria in the Washington State sediment management
standards for benthic toxicity.”
Note: The distinction for benthic chemical criteria needs to be made because the WA SMS criteria
also apply to bioaccumulative standards for human and ecological health – which are different.

Suggested edit to “Ongoing programs”, page 143; Key ongoing program activities/bullets 1, 2, 3:
Performance metric: Performance metrics Cleanup milestones for the Bellingham Bay Demonstration
Pilot Project vary by individual project components. For example, pProgress on milestones for the
cleanup of contaminated sites in Bellingham Bay are viewable at Ecology’s website:

Ecology’s Toxics Cleanup Program worked with PSP in August 2011 to update Near Term Actions for
this section. Those updated NTA actions are:
- Former B.2.N2, updated NTA: Focused efforts on three significant cleanup and habitat restoration
projects in Bellingham Bay: Cornwall Ave, Whatcom Waterway, and G-P Mill.
- Former B.2.N3, updated NTA: Continue to control pollutant sources and remediate toxics in the
Lower Duwamish.
B1. Use anticipated population and economic growth as a catalyst for recovery by building on
existing efforts to establish protection and restoration priorities.
B1.1 Ensure complete, accurate and recent information directly assists shoreline planning and
decision making at the site-specific and regional levels

Recommendations:
NTA1: Explain how this action of “developing work plan for network of MPAs in P.S.” contributes to
present and future MSP planning in Puget Sound. Provide context for how this fits into future
planning and larger scope. For example, the development of the MPA work plan will lay out a
framework for interagency coordination and decision making for the establishment of MPAs in P.S.
Coordination and information exchange is a crucial element of MSP at all scales, across jurisdictions
and between sectors. It seems that discussion of MPAs fits better under B2 under ‘protect and
conserve relatively intach ecosystems’.

NTA2: Include discussion of how this action “ID human use patterns for MPAs in PS” contributes to
present and future MSP planning in Puget Sound. For example this information provides information
on where conflicts and certain types of impacts occur in the marine environment which can be used
in the establishment of MPAs. This data set can also be used to support data sets collected in A1 by
identifying areas that are heavily used by the recreation and fishing communities bridging gaps in
ecological/ social interaction and terrestrial/ marine relationship in human uses.

B2. Protect and conserve relatively intact ecosystems to maintain the health of Puget Sound.
B2.1.Take actions that protect priority nearshore physical and ecological processes consistent with
the Soundwide restoration priorities identified in B1.1

Recommendation: Cite the connection of this action to MSP. “If the priorities identified in B1.1 are
recognized and incorporated into local comprehensive plans and zoning ordinances, the
prioritization can help planners, restoration practitioners, and other decision-makers direct growth
away from existing areas of high ecological value and towards areas where resource conservation is
not the primary objective.”
P. 116 There should be specific mention that MPA planning should not be done in isolation from
planning done for terrestrial protected areas.
P.125 and 138 Although the idea behind GreenShores (p.125 and 138) has been expanded as
originally suggested by Environment Canada (in our comments related to the 2008 PSP Action Plan),
we would prefer to see more action items stemming from this, as opposed to the brief mention that
some BC-Washington work is occurring.
Page 113. Nearshore habitat – general comment and logic chain.
• This logic chain and thus this set of “B” strategies are missing a key piece: retrofits for existing built areas and existing
damaged areas. The focus of these strategies is on restoring high priority locations or high priority processes, which is
important, but what is missing is holding the line on more damage and reversing the damage. Admittedly, this is a challenging
issue to tackle and it may take decades, but the Action Agenda should not ignore this arena. B1 assumes only environmental
improvements when there is new development or significant re-development. This leaves a gap for existing areas. Examples
could include incentives for homeowners (who are not in the process of doing a remodel or other project that would trigger
SMA) to remove overwater coverage or tax benefits if homeowners rip out existing paved areas or plant native vegetation.
Education (Bxx) is not adequate. Many of the Actions and near-term actions listed under B3 (priority restoration) would fall
under our recommended new strategy. Then B3 could be better focused on priority restoration actions. Currently, these
various strategies and actions appear to be comingled.
• The gap is not only for existing areas, but also for site specific compensatory mitigation for undeveloped areas. In our recent
experiences with two Shoreline Master Programs (note: not marine areas) Kenmore and Bothell-- the difference between
undeveloped areas with relatively intact riparian vegetation and retrofits for existing built areas and existing damaged areas
are ignored and it is simply assumed that all shoreline areas are to be developed under regulations that address retrofits and
existing damaged areas as if they are the only shoreline riparian areas remaining. The compensatory action for development is
ignored in the regulations.
Page 116. Shoreline protection – general comment. The draft Action Agenda is missing a key need – upgrades and better
regulation and implementation. Currently SMA regulations (and other regulations) are not adequate to provide the needed
protection for Puget Sound. An action is needed that includes regulatory reform and upgrades rather than having this issue
listed as an emerging issue at the end of the B3 strategy. If C1.1 (Implement and strengthen authorities and programs to
prevent toxic chemicals from entering the Puget Sound environment) is listed as an action, then a similar regulatory-related
action is appropriate here.
Page 116. Shoreline planning assistance (B1.1).
• There seems to be a disconnect between the near-term actions associated with this substrategy. The strategy is about a
critical need – more assistance for the planners working on SMP, GMA, etc. This assistance should NOT come in the payment
and hiring of consultants. A third party (with their own agenda) is introduced into the local planning process. Consultants
“interpret" for the local planners what they believe Ecology requires and local citizens are left defenseless.
• The near-term action is about marine reserves – another important need. We recommend that a new substrategy be created
that relates to marine reserves and that these near-term actions be placed there. In addition, more information about what
Ecology, DNR and other agencies are doing to improve their respective programs would be helpful under ongoing programs
In B2.4 and B2.5, SAV and MPAs should be protected from the effects associated with potential CC scenarios. The majority of local strategies come from the San Juan
Islands; examples from other areas around the Sound should also be included.

Change “Shoreline Master Plans” to “Shoreline Master Programs” here and throughout the document.
B1.1 (page 116) - The opening paragraph indicates that there is a need to reconcile the PSNERP priorities with other rankings. The Action Agenda needs to identify an
ongoing program or NTA that will accomplish this as it is a necessary next step and is referred to in subsequent strategies.

The “Ongoing Programs” section needs more detail to achieve the “goal” stated in the second sentence, or needs an NTA to achieve that goal. There are several
mentions of MPAs which are primarily limited to offshore areas here, but there is less content on protected nearshore habitat. There needs to be actions to focus on
information and monitoring of those types of sites as well. The strategies in this section do not appear to address marine and nearshore restoration priorities identified
by PSNERP. These should either be called out under NTA 1 or a new NTA should be identified to address this need.

B1.3, LNTA 1 (page 118) – Specify which kinds of permit applicants will be eligible for on-site technical assistance.

B2.1 (page 121) -The analysis mentioned in the first paragraph as occurring in B1.1 is not actually listed under that NTA.
(page 122) - Mention here that Ecology also has review and approval authority, rather than just supporting locals.

B2.1, NTA 2 (page 123) - This NTA contains two very different goals. We suggest breaking this action apart into two NTAs or choosing one to focus on.

B2.1, LNTA3- It is unclear what value this action adds beyond listing ongoing efforts in the region. Describe the action more clearly to state what it is and integrate it with
the performance measurement.
At the bottom of the page there is again a reference to restoration priorities identified in section B1.1 when that action is not specifically called out there.

B2.2 (page 124) - In the first sentence, the HC and SMA are the two principal State regulatory authorities for shoreline armoring…

B2.3 (page 125) – An NTA should be created to address permanent removal of armoring.

B2.4 (page 127) -This is a good suite of NTAs that address the issue from multiple perspectives.

B2.5 (page 128) -There is no mention of tribes under this strategy yet they are a key player in this issue and must be part of discussions.

B2.5 NTA 1 is incomplete.

B2.5, LNTA 2 & 3- Footnote 13 on Page 65 refers to the PSP Floodplain Management paper. Is that the work that was intended to be cited here? Re-cite on this page or
add correct footnote.
It is unclear whether A1 will delve into offshore marine issues.

B2.6 (page 129) - The last sentence of the 2nd paragraph under “Ongoing programs” should read: “The objective of the guidebook is to further the goal,” not “The
objective of the guidebook is further the goal”

B2.6 NTA 1(page 130) – “[Who] in coordination with DNR, will create a coordinated permit review and decision making process for shoreline substantial development
permits [other types of permits?] to provide additional efficiency and predictability for applicants and promote permitting agencies working together to ensure nearshore
protection.” This NTA seems to overlap with both A4 NTA1 and with some existing permit coordination forums (e.g. CWA section 401/404 pre-notification meetings and
the interagency nationwide permit team). These respective NTAs should be coordinated in order to better use existing interagency review forums and to determine how
to fill specific gaps in specific types of permit reviews. The performance measure could involve providing recommendations for using or modifying existing permit review
staff and procedures to address specific priority permit review coordination.
Substantial Development Permits are issued by local governments and can be reviewed by Ecology (not DNR). Both local government and Ecology need to be involved in
this action, not necessarily DNR, unless other permits are being reviewed as well.
Page 116. Shoreline planning assistance (B1.1). More information about what Ecology, DNR and
other agencies are doing to improve their respective programs would be helpful under ongoing
programs. (E.g. what has been done to enhance the conservation of areas recently designated as
Aquatic Reserves)

Page 138. Marine debris removal (B3.3). Efforts should be made to replace creosote pilings nearby
herring spawning beds given their sensitivity to PAHs. Incorporation of acute and chronic Herring
bioassays developed by Ecology need to be made part of all refinery NPDES permits. These studies
need to account for daylight conditions given the significant impacts associated with UV enhanced
toxicity.
The PSPs role in promoting local implementation is extremely important, and there should be a
sound-wide NTA that recognizes and fosters local implementation. This includes programmatic
activities (such as shoreline management planning in NTA B.2.1.3) as well as support for
development and implementation of specific projects. Specific local projects are individually and
cumulatively very important to Puget Sound recovery (see related comment on prioritization).
• Many of the NTAs regarding shoreline protection appear to adopt the same approach as NTAs in
the land use section, emphasizing voluntary action. More positive or negative incentives may be
needed.
Strategy B.1.1, NTA 2:
This NTA should be eliminated, or at a minimum, clarify that marine spatial planning shall not
supersede local control over land use decisions.
Strategy B.2.6, NTA 1:
We would have major concerns with this particular action were it to result in a slower permitting
process for shoreline substantial development permits. We also question whether this action is
feasible from a staffing standpoint. Do local governments have the capacity to engage in this
additional review process with DNR? There are already too many redundant regulatory requirements
in permitting processes. Don’t create another hurdle, which only increases cost and encourages
delay.
NTAs we support:
With regard to shorelines, we would support the use of incentives to encourage removal of armoring
and use of soft armoring techniques when bulkheads fail, need repair, and during redevelopment.
Strategy B.3.2, NTAs 1 & 2 appear to be reasonable approaches to incentivize these types of actions,
assuming a funding source can be found for the loan program. In general, we believe the use of
incentives, along with education and outreach to shoreline property owners, is the preferred way to
address concerns aboutto BNSF and single-family shoreline properties. The action plan regulations
Armoring: Also relates shoreline armoring, as opposed to new regulations. Increasing focuses on
Substantial Development permits – we are addressing these, but the majority of shoreline is exempt
under Single Family. Education and the pilot programs mentioned will be a step in the right
direction.

Marine Protection Areas: Implementing a network of MPAs. This requires working with Tribal
governments that have the rights of harvest, and thus the existing MPAs and any new ones require
their approval. Without tribal approvals you do not have MPAs. They should also be referred to as
Marine Management Areas (MMAs).

Nearshore Funding: The nearshore has been neglected while scientists try to agree on best
approaches – this needs to change – we have examples proving nearshore enhancement/restoration
works, and we also know where additional sites will provide benefit. We need to move forward.
The proposed strategies are reasonable and could be enhanced if more specific NTAs were added to
ensure targets will be met.
B1. Use anticipated population and economic growth as a catalyst for recovery by building on
existing efforts to establish protection and restoration priorities.

B1.1 Ensure complete, accurate and recent information directly assists shoreline planning and
decision making at the site-specific and regional levels.” In the near term, we recommend the
Partnership work directly with each county and city to “ensure complete, accurate and recent
information directly assists shoreline planning and decision making” rather than focusing on marine
protected areas. We agree the most recent and accurate information should be used in decision-
making at all levels of government.

B1.2 Monitor projects to effectively evaluate results and implement adaptive management. We
recommend this sub-strategy focus on establishing greater Sound-wide monitoring, including
stratified sampling of all coastal landforms and habitats, including restoration projects rather than
limiting monitoring to Aquatic Reserves.

B1.3 Use outreach and education to encourage actions to protect and restore nearshore and marine
habitats. We suggest the Partnership include additional NTAs for all Puget Sound counties.

B2.6 Give permitting agencies and local governments the tools and resources they need to ensure
protection of nearshore and marine environments.” We recommend the Partnership expand the
NTAs for this sub-strategy to ensure necessary protection will result. For example, the Partnership or
Nearshore and marine protection and restoration: This section should acknowledge sea level rise that is expected to occur to varying degrees throughout Puget Sound. A
change in sea level will affect decisions associated with shoreline planning, restoration, armoring and other issues.
p. 116
Ongoing Programs: (Add) Northwest Straits Initiative as an entity that is providing information relevant to B1.1. Reconsider the current list of on-going programs which
are more accurately regulations and codes, not programs.
Near Term Action: (Add) Northwest Straits Initiative will expand SoundIQ web application to streamline and improve availability of nearshore data for use by local and
state governments and agencies. SoundIQ is a data platform that is being populated with data from several MRCs, county governments, and state agencies.
p. 117 B 1.2
Ongoing Programs: (Add) Northwest Straits Initiative, monitoring is a key component of work by MRCs in 7 counties.
Near Term Action: (Add) Continued monitoring of nearshore resources and habitats by Northwest Straits Initiative.
p. 118 B1.3
Ongoing Programs: (Add) Northwest Straits Initiative promotes stewardship, local community education programs and protection of nearshore habitats through the work
of 7 MRCs and regional programs coordinated by the Northwest Straits Commission.
(Add) Marine Stewardship Areas established by local MRCs and partner organizations in Port Susan and San Juan county waters are on-going projects to raise community
awareness to take actions to protect 'relatively intact ecosystems'.
Change 'Marine Recovery Councils' to Marine Resources Committees.
Near Term Action: (Add) Northwest Straits Initiative will hold workshops in 7 counties to educate residents and landowners about drift cells, shoreline geology,
appropriate use of armoring and softshore alternatives.
p. 123 B 2.1
Near Term Action: (Add) Clallam and Jefferson MRCs as a mechanism for providing substantive public input on topics listed to county governments.
p. 126 B 2.4
Ongoing Programs: (Add) Northwest Straits Initiative through its Jefferson County MRC established voluntary no-anchor zones to protect eelgrass beds. (In Port
Townsend, where rich eelgrass beds are close to city piers and docks, compliance is 99%.)
(Add) Northwest Straits Initiative as lead on eelgrass and other topical issues across Puget Sound Basin.
Near Term Action: Northwest Straits Initiative will continue to protect eelgrass beds through education, outreach, and no-anchor zones. Three new voluntary no-anchor
zones to protect eelgrass beds will be established in other locations of Puget Sound.
p. 127 B2.6
Ongoing Programs: (Add) Northwest Straits Initiative, through its 7 MRCs, provides scientific and monitoring data and other information on local shoreline resources to
local elected officials.
Near Term Action: (Add) Northwest Straits Initiative, through its 7 MRCs, will continue to collect local data and advise elected officials and planning departments.
Northwest Straits Initiative through 7 MRCs will act as convener around issues of local priority (i.e. bulkheads, setbacks, finfish aquaculture) in Shoreline Master Plan
(SMP) updates
p.136 B 3.1
Ongoing Programs: (Add) Northwest Straits Initiative, through its 7 MRCs, identifies local shoreline restoration projects that are often carried out in partnership with non-
profit organizations and public landowners.
Near Term Action: (Add) Northwest Straits Initiative will carry out local nearshore restoration projects with a goal of restoring 10,000 linear feet of shoreline.
p. 139 B 3.3
Ongoing Programs: As written this is not correct. The Northwest Straits Initiative is the lead organization doing derelict fishing gear removal in Puget Sound. NWSI works
in coordination with WDFW to accomplish projects. DNR is not actively engaged with derelict gear removal.
Near Term Action: (Add) Northwest Straits Initiative will remove the remaining 500 nets in shallow water by the end of 2013.
Move section on derelict gear to species recovery. (Derelict net removal is a recommended action that is in state and federal rockfish recovery plans.)
p. 112
The sentence "This chapter describes eight overarching strategies" should end in 'marine and nearshore ecosystems' (rather than upland and terrestrial)
B2.4 NTA 3
State Parks NTA 1: DNR, in consultation with WDFW, Ecology, RCO, and State Parks will publish
design guidance on construction, repair and rebuilding of overwater structures to increase light by
2012 (Appendix D, p. 490).

Comment: State Parks staff has not had the opportunity to discuss the scope of this item with Puget
Sound Partnership staff. Please note that we would like to include this item for discussion at our
February 10, 2012 scheduled meeting.

B3.4 NTA 1
State Parks NTA 2: State Parks will identify opportunities to provide nearshore restoration including
removing hard armoring at Parks and will implement at least [number] feet of nearshore restoration
including armoring removal by [date] (Appendix D, p.491).

Comment: Thank you for incorporating earlier comments submitted via email by State Parks on
November 3, 2011. Hard armoring removal is one type of restoration conducted by State Parks.
Related nearshore restoration projects include beach debris removal, habit enhancement projects,
retrofitting dock facilities to encourage eel grass and replacement of outdated mooring buoy anchors
with helical anchors. At our upcoming meeting we look forward to discussing details related to
number of feet of restoration to occur and the date by which that restoration would occur.

B3.4 NTA 2
State Parks NTA 3: DNR will convene appropriate state agencies such as WDFW and State Parks to
prioritize restoration projects within protected landscapes such as Aquatic Reserves and State parks
to ensure maximum long-term benefit from habitat restoration (Appendix D, p.491).
p. 141-144 - We support actions to improve environmental protection at marinas and working
waterfronts through marine spatial planning. In addition to environmental protection, waterfront
planning should protect cultural and tribal resources in those areas. For example, tribal resources
and culturally sensitive areas near Port Gamble Bay are in direct conflict with local industrial and
development activities and plans.

In addition, marine spatial planning should be consistent with MTCA cleanup actions and other
federal, state, tribal, and local environmental protection and restoration programs underway.



B1.3 LNTA 1 – This San Juan LNTA does not fit perfectly under the sub-strategy “Use outreach and
education to encourage actions to protect and restore nearshore and marine habitats.” While
education and outreach is certainly a major piece of this, the focus is on on-site assistance to
landowners. Coupled with the salmon recovery strategy, this basic level of local capacity forms the
protection strategy for the San Juan Action Agenda in the near-term. Maybe there is another sub-
strategy needed here related to technical assistance.

The key distinction is in the local strategy:
“Provide information and work with landowners regarding the importance of retaining and restoring
native vegetation, trees and ground cover and geologic processes.”
NTA B.2.1 would take actions that protect priority nearshore physical and ecological processes
consistent with the Soundwide restoration priorities identified in B1.1. Renton supports Ecology
continuing to provide funding and technical assistance to local governments for the development
and implementation of new regulations that are required by the state to be adopted and
implemented by local governments.

NTA B.2.4 would take actions to protect migratory corridors and vegetation particularly in sensitive
areas such as eelgrass beds. We question whether this applies only to marine nearshore areas or
whether it could also apply to river and lake tributaries to Puget Sound. Private property owner
input, along with local government input, will be needed as part of any WAC revision. Allowances for
public overwater structures should be considered if the access to the shoreline is going to be limited.

 B1.1: This sub-strategy, as it relates to shoreline planning, fails to include the possibility of changes
to regulations. It lists continuation of existing codes and regulations and calls for the development of
a comprehensive set of priorities, but this strategy should include possible changes to existing codes
and regulations. (p. 116)
B2.2, NTA: Projected sea-level rise should be considered when making modifications to hydraulic
code. (p. 125)
B2.5: The Nature Conservancy is listed as the NGO to participate with government agencies to
evaluate marine protected areas. If an NGO is involved in such a process, it should be open for any
and all organizations to bid for participation. (p. 128)
B3.3: The only priority marine restoration action identified in this sub-strategy is the removal of
derelict fishing gear, vessels, and creosote treated wood. The sub-strategy is titled, “Implement
priority marine restoration actions consistent with the Sound wide restoration priorities identified in
B1.1,” however the focus is solely removal of marine debris. The section should be titled, instead,
“Removal of marine debris,” or should be broadened to include other actions. (p. 138)
B1 Use anticipated population and economic growth as a catalyst for recovery by building on existing efforts to establish
protection and restoration priorities

B1.1 Ensure complete, accurate and recent information directly assists shoreline planning and decision making at the site
specific and regional levels
Comment: Great ideas, but who will do this and when? How will it be funded? The description should include mention of the
shoreline restoration plans being developed under local SMPs.

B1.2 Monitor projects to effectively evaluate results and implement adaptive management
Comment: This is important to do for all projects, but the usual obstacle is finding the funding. Appears from description that
this is only referring to those projects funded by ESRP. Is that the case, or are other projects included?

Mitigation projects should be included in monitoring to determine if the mitigation that is required is achieving the required
compensation for the impact caused by a project. Dedicated funding is needed for this because the cost to do business,
mitigate for impacts and monitor will be a very big issue if funding for monitoring does not come from another source.

B1.3 Use outreach and education to encourage actions to protect and restore nearshore and marine habitats
Comment: Again, who is expected to do this, when and how funded? Just the list under ongoing programs?

B2 Shoreline Armoring
B2.1 Take actions that protect priority nearshore physical and ecological processes consistent with the Soundwide restoration
priorities in B1.1
Comment: Good to include reference to salmon recovery plans in this section, as they also identify priorities for protection
and restoration based on science for each WRIA. This includes the more urban systems where it is still important to ensure
shoreline habitat for salmon.
Also shoreline restoration plans identify areas that need protection/restoration. For both these types of plans, finding the
funding is a barrier.

B2.2 Prevent new shoreline armoring except where it is required to protect existing infrastructure from imminent risk
Comment: In the description, reference is made to a variety of ways to make this happen, including using soft shore methods.
Recommend adding to strategy: “Use soft shore techniques where feasible”. Ecology’s Shoreline Master Program Guidelines
include many standards for new shoreline armoring and bulkhead armoring. These guidelines should be reviewed to
determine how close they are to the recommendations. If recommendations are different then an additional action item (or
strategy) to change the guidelines should be made to the state legislature to ensure that the recommendations are followed.

B2.3 Where armoring is aging or non-protective, seek opportunities for permanent removal or the use of soft armoring
replacement or landward setback techniques.
B3.2 Provide incentives to encourage removal of armoring and B3.2 NTA 2: Recognition program to
highlight retrofits, redevelopments, bulkhead removals, and soft shoreline projects

Comment: Regarding the performance measures: Program in place or not; number of awards
This should be modified to include the toxics issue associated with creosote pilings
B2.2 Prevent new shoreline armoring except where it is required to protect existing infrastructure
from imminent risk.

Please see our comments under A5.1 NTA 1 which apply to this section as well. Again, we can’t
stress enough what a difficult problem shoreline armoring is. Log jams and soft armoring techniques
should be utilized to encourage Chinook salmon habitat and efforts must be made to remove
infrastructure from the floodplain.

B2.6 Give permitting agencies and local governments the tools and resources they need to ensure
protection of nearshore and marine environments.

Aside from the question of whether or not current regulations are providing adequate protection for
these environments, another significant issue is enforcement. Many local jurisdictions lack the
funding to effectively enforce regulations at the current level. Staffing and equipment shortages,
more common in our struggling economy, mean that enforcement personnel lack the resources
needed to ensure the proper permits are being issued and that permits that are issued are being
properly adhered to. The Stillaguamish Tribe encourages the Partnership to provide local
jurisdictions the resources necessary to perform these vital functions.

Additionally, most permitting violations are handled in the criminal court system along side serious
Under the Marine Nearshore B1.1 pg 116. "Ensure complete, accurate and recent information
directly assists shoreline planning and decision making at the site specific and regional levels". B1.1
NTA 1: PSP will develop a work plan for implementing a network of marine protected area in Puget
Sound. Any further discussions surrounding this item need the attention of Tribal leaders, who have
voiced repeated concern over the use and validity of these preserves. A broad range of other
management tools and actions must be implemented to enhance and or protect natural resources
prior to even examining the scientific validity on a case by case review of these MPA's as a recovery
tool. Ultimately these reserves remove areas from the already limited usual and accustomed fishing
grounds for the Tribe's to exercise Treaty Rights. Consequently there is a lack of Tribal policy support
for such actions.
Potential Suggestion for Initiative/Strategy: A Coastal and Marine Nearshore Retreat Initiative:
introduce retreat as an option for coastal landowners. This could be an State/Federal incentive
program either through SMP implementation or FEMA/NOAA/FWS/ Local and trusts, that could work
with interested coastal bluff and other nearshore landowners Coastal spits/embayments) that are
willing to have their house moved back out of the zone of impact, and restore habitat, or have a life
estate on their property with the end point being structure removal and restoration of habitat. This
would address future issues with sea level rise, other climate change impacts, and also provide more
public access to the Puget Sound shoreline. Areas could be prioritized using the Cereghino strategy
document, species recovery plans, PSNERP information, or habitat/ecosystem process benefits.

B.2.1 NTA1: The "who" for this task could be WDFW/WDNR through implementation/funding from
EPA for the Marine and Near shore Component. WDOE/WDFW/WDNR/WSP/Tribes can access State
and FWS/NOAA Coastal federal grant programs for this type of habitat protection.
B.2.4 NTA 3: Opportunity for Federal regulatory agency engagement in development of overwater
structure guidance.
B3. Text section Pg. 134: Include FWS in Federal Agency bullet.
B3.1 NTA1: The "who" for this task could be state, federal, tribal, and local agencies and
organizations who have made the commitment to work on PSNERP, and who are interested in seeing
the projects through to construction, either through ACOE or other local/state/federal/tribal efforts.
B.3.2 NTA 1/2: The "who" could be WDNR/WDFW through implementation/funding from EPA for
Page 118, Change “Washington Sea Grant Program” to “Washington Sea Grant” in both lines where
it appears.
Page 118, under Ongoing Programs, bullet point 1, please add a sentence: “Sea Grant specialists
educate the public on shellfish, stormwater, shoreline restoration, onsite sewage system
maintenance, and other important issues.”

Strategies B1 and B2, pages 114-130:
We support efforts of the PSP to investigate and encourage establishment of a network of Marine
Protected Areas. The science is clear that MPAs have been successful worldwide and that there is no
credible reason why MPAs would not be a powerful tool to help recover the Sound and its species.
Efforts to establish a network of MPAs in Puget Sound should be coordinated with those of Canada’s
federal government as well as the Province of British Columbia.

Page 154
DNR manages the wildstock geoduck fishery and does not recognize geoduck as "imperiled," as
claimed in B.7.2.2.

Page 153. Species recovery (B7). The draft Action Agenda continues the catch-22 of recovery plans.
The Recovery Plans rely on the Action Agenda to make specific improvements and now the Action
Agenda in turn states that the recovery plans
should be implemented. This is a challenge because the specific actions are therefore not articulated
in either location – the Action Agenda or the Recovery Plan. The Southern Resident Killer Whale
Recovery Plan, for example, does not include specific actions needed for recovery but instead relies
on a research approach. Somewhere, somehow, the actual actions need to be articulated. If the
Partnership feels that it is not possible for the Action Agenda to include these specifics, then the
Action (B7) should be “NOAA will produce a Recovery Plan with specific articulated, measurable
actions that will ensure recovery of x population.”
Page 155. Target View: Pacific Herring. This statement is vague: “Efforts to help the recovery of
Cherry Point herring have been taken, but we have yet to see their population turn around.” Little
other than stopping the fishery has been done which is evident from the second statement with
which we agree, “More needs to be done to understand the causes of the decline.” If there are
B7.1 (page 153)than curtailment of the fishery, please add that inimplements them, what their goals
activities other – Explain the existing biodiversity plans (i.e. who this section.
are, what actions they encompass) as well as who is charged with developing a more integrated
planning approach and why it is necessary.

B7.2 (page 156) - Other strategies also relate to herring. It may be appropriate, given the herring
target, to develop a specific action related to herring under this strategy? If all work is focusing on
B3, maybe the Target View sheet should be moved there instead of following B7. Other potential
strategies that will contribute to orca recovery should be included in this diagram.


Page 155. The statement “Efforts to help the recovery of Cherry Point herring have been taken, but
we have yet to see their population turn around” is quite vague and misleading. Little more than
stopping the fishery has been done which is evident from the second statement with which we
agree, “More needs to be done to understand the causes of the decline.” Particular attention needs
to be placed on current behavioral responses to dock operations as well as historic oil spills that
occurred during herring spawning seasons.
p. 153 B 7.1
Near Term Action: (Add) Port Susan Marine Stewardship Area is a mechanism to fill data gaps
identified in this area of Puget Sound in 2011.
B7: In general, this section relating to strategies to recover marine and nearshore species is lacking
detail.
B7.1: More information about the kind and progress of current biodiversity plans would be very
helpful for this sub-strategy. At this point, the sub-strategy is too vague to be effective. (p. 153)
B7.2, NTA’s: Performance measures and timelines for the implementation of these recovery plans
need to be developed. Without such markers for progress, including these goals in the action
agenda appears to be an empty gesture. (p. 154)


Although the decline of marine birds is noted as an issue in the document, we could not find any
strategies that address this decline, or any acknowledgement that marine birds will benefit from
conservation and restoration actions noted in the Marine and Nearshore sections.

B7.2.1 NTA 1/2: It should be noted that FWS and NOAA also prioritize implementation of restoration
and recovery projects identified within species recovery plans.
logic model
Comment: Logic models difficult to read
Recommended Edit: Increase size of text, size of paper, or move to dedicated appendix.
logic model
Comment: Some strategies likely easier to implement and others have huge constraints but these differences aren't apparent in model. Models are not well integrated with text. By 2020 where will we
be in relation to implementing strategies?
Recommended Edit: Suggest some way of visually showing which strategies are higher priorities and/or which ones need more effort because they are difficult. It would be useful for the graphic to
distinguish between what strategies can be done with a little effort or are already being done.
logic model
Comment: The section really doesn't get at what the major constraints to implementation are
Recommended Edit: Identify the major limitations to implementing recovery actions and describe if/how they are to be addressed.
Targets
Comment: There is no text accompanying the introduction of the targets to explain how they were developed, how they are intended to be used, or even whether all aspects of the targets are
currently being monitored. The targets can be used to help us plan or bring focus to our work, but this is not the purpose for which the indicators were originally developed, and they do not represent
all aspects of recovery that we need to consider. Moreover, some of the targets are incomplete as presented throughout the document, and seem to be using the simplification of targets that was
included on the Vital Signs website; for example, the Toxics in Fish target refers solely to a single class of contaminants in the Action Agenda, whereas the complete target refers to a wider range of
contaminants.
Recommended Edit: Include language to describe the indicator development and Target selection process, the purpose(s) of the targets, and a clearer evaluation of the adequacy of each target. Use
accurate language to describe the targets in subsequent parts of the document (e.g., "target views")
Logic Model - Land Development
Comment: The logic model does not include the recovery target (dark green square)
Recommended Edit: Update logic model.
Comment: Intermediate results do not consistently line up with actions. The action is “Improve local gov ability to implement plans, regs and permits consistent with PS recovery.” One intermediate
results is “increased state technical support to locals” How? From where? Nothing in the text addresses how the state will increase its technical support to feed this action.
Recommended Edit: Update logic model.
Target View Estuaries
Comment: The target view of estuaries does not belong following "public access to shorelines" in the table of contents. The other target views seem to follow the sections that have the most to do
with achieving the target. If that is true, the estuary target view should be nested in the marine and nearshore protection and restoration section.
Recommended Edit: Move this target view to somewhere in the marine and nearshore protection and restoration section. Probably after B2 or B3.
Logic model -- Shoreline Armoring (p. 133)
Comment: There are strategies that realistically can not be implemented without significant change.- It would be helpful to clarify which strategies can be implemented relatively easy and which will
require a significant effort.
Recommended Edit: Differentiate between strategies that can be implemented relatively easily and which will required dedicated focus and which may practically not be implemented.
Target View - Eelgrass
Comment: How is this target affected by the weed board’s declaration of z japonica a noxious weed, which seems to allow or even encourage the reduction of eelgrass generally in Puget Sound?
Recommended Edit: Question only. Perhaps clarifying language would be helpful?
Target View -- Herring
Comment: There is a mismatch between the target and the recovery NTAs. All recovery NTAs for this section are in B.3. Implement and maintain priority nearshore and marine ecosystem restoration
projects. Most of the B.3. NTAs refer to PSNERP projects designed to recover shoreline, and removal of shoreline armoring and derelict nets. None of these projects directly impacts herring abundance
in any obvious way. Although herring spawn in the nearshore it is not clear that shoreline armoring or other shoreline habitat changes have impacted herring reproduction. Further, it is not clear that
herring abundance is in any way limited by the availability of undeveloped or restored shoreline. In addition, the stated primary concern re: herring is the decline of the Cherry Point stock, where little
shoreline development has occurred, except for the industrial piers (which are not mentioned in B.3.). The bottom line here is that we could adopt all the NTAs in B.3. and there would likely be no
effect on herring abundance. There is no single proposed NTA that is directly related to the stated target, Herring Abundance.
Recommended Edit: Recommend a thorough review of strategies and NTAs related to this target, but also all targets. This may require significant work and a significant revision of the existing draft.
Target View - Shoreline Armoring
Comment: Similar to the above comment on the Target View for Herring: How confident are we that the strategies laid out here will really lead to a reduction of shoreline armoring as described in the
Target View?
Recommended Edit: As above, recommend a thorough review of strategies and NTAs related to this target, but also all targets. This may require significant work and a significant revision of the
existing draft.
Comment: Figure legend inaccurate.
Recommended Edit: Modify text: "The graph below shows the change in shoreline armoring in Puget Sound between 2005 and 2010. "
Comment: Text lists "implement and maintain priority floodplain restoration projects" as a relevant strategy but this target is about marine shorelines -- confusing.
Recommended Edit: Verify that A.5.3 pertains to shoreline armoring, or eliminate from list of related strategies.
Logic model -- Toxics in Fish (p. 268)
Comment: The logic model for Toxics in Fish is unbalanced. There is too much detail in the Drivers and Pressures section (left side), and too little in the Impacts section (right side). Although prevention
The target views and results chains diagrams.

Since near-term actions end in 2013, the “target views” clearly are not complete. In some cases, the
target views omit critical actions, like water quality improvements for eelgrass. The results chains are
illegible. A theory of change that does not include an institutional analysis of the 25-year history of
barriers to implementation of the Puget Sound Management Plan is clearly incomplete and flawed.
PSP is to be commended for the work it has done, but its presentation undermines the most
important goal of any plan – to be understandable and compelling so that it can serve as a roadmap
for action. To put it in DNR terms, one cannot see the forest for the trees.

Page 155, Pacific Herring, and Page 157, Orcas
No strategy is offered to achieve either the Pacific Herring or the Orca recovery targets. At minimum,
these sections should list the relevant NTAs as other "Target Views" have done.

The results chain diagrams aren’t legible when printed and aren’t labeled and referenced in the text.
Use of multiple, overlapping diagrams in some sections (e.g., wastewater) seems inefficient.

Apply the following edits to all versions of the wastewater diagrams on pages 210, 213, and 220.

p.210 - Diagram: substitute LOSS for large OSS throughout the diagram.

p.210 - Diagram, Strategy C5.3: Rewrite to be consistent with strategy C5.3 on page 217. Suggest
rewriting both to say “Improve and expand funding options for on-site sewage systems and local OSS
programs.” This allows consideration of LOSS funding needs. (see same comment on strategy C5.3 on
p. 217)

p.210 - Diagram, Intermediate Funding Result for C5.3: Edit second box to say “Funding available to
repair, maintain, and replace OSS and LOSS.”

p.210 - Diagram, Intermediate LOSS Result for C5.2: Edit second box to say, “LOSS comply with rule
requirements.”

p.210 - Diagram, Intermediate OSS O&M Result for C5.1 and C5.2: Given the connecting line from the
two strategies, retitle this intermediate result as “OSS and LOSS O&M,” and change second box to
say, “owners properly operate, maintain OSS and LOSS.”

p.210 - Diagram, OSS Pressure Reduction Result: Suggest editing this pressure reduction result to say
“reduced pollution from OSS and LOSS.”

p.219 - Target View: Change title to, “Target View: On-Site Sewage System Management.”

p.220 - Target View, last paragraph: The text refers to green ovals (ecosystem change) and green
squares (recovery targets) although there are none in the diagram.
Target views and results chain diagrams. It is not possible to definitively state we have all we need to
reach recovery targets, but the proposed strategies, sub-strategies and NTAs – supplemented with
better characterization of key ongoing programs – provide a sufficient framework to have the
discussion. In addition:
a) We believe the results chains are important to “show your work” and document the logic behind
the strategies. However, they are difficult for the average reader to follow or understand. We
suggest placing the results chains in an appendix.
b) The primary gaps we see are the absence of key benchmarks that describe the environmental
and/or policy milestones needed over the next eight years to achieve the 2020 recovery goal.
c) We support the presentation of target views help to focus the public and decision makers on the
key elements of the Action Agenda: Specifically, what we are managing toward (i.e., targets) and the
primary means we use to get there (i.e., strategies and sub-strategies). Again, adding in benchmarks
will complete the picture.

Target View: Marine Sediment Quality, page 269-70: Note: It is important to note some limitations to
the SCI /SQTI calculations and sampling efforts. The SCI /SQTI are measurements of the health of the
benthic community. These measurements do not reflect sediment quality related to bioaccumulative
chemical impacts to either human health or ecological risk and do not reflect sediment quality in the
nearshore environment where the majority of cleanup sites are located. The SMS and MTCA require
analysis of benthic community impact as well as human health and ecological risk from
bioaccumulative chemicals. As this section is written, the public will not understand why the SCI
/SQTI shows most regions as minimally impacted, and some as not impacted, while the Toxics
Cleanup Program has identified these regions as impacted and requiring cleanup under the SMS and
MTCA. For example, the South Sound has a score of “unimpacted” because it is above the SQTI
target of 83. However, Budd Inlet has a number of cleanup sites that impact both the benthic
It's hard to know whether the items in the diagrams will really accomplish what's needed as there
are so many steps along the chains that may be broken. It's notable that a number of Science Plan
items aim to increase understanding around restoration actions. It remains to be seen whether these
chains, if carried out from beginning to end, would indeed result in the desired outcomes. In general,
the resolution of the diagrams is low making them difficult to read.


PSP Vital Signs The EPA-EC Transboundary Indicators project has updated its report to reflect metrics
that correspond to the vital signs indicators. Stronger communication between the PSP and
transboundary agencies could extend the reach of the PSP indicators to facilitate cross border
collaboration on the Salish Sea.
 • We commented previously and here comment again that it would be more beneficial for the
reader if simpler chains (see Attachment 2 for three examples we have drawn up) were used in the
text and the more detailed (and more difficult to read) Miradi diagrams were incorporated in an
appendix.
 • In addition, the logic chains should be for the full recovery, not terminated at 2020. 2020 is a
midpoint on the road to recovery.

Page 31. Logic chain. This chain does not easily read to the viewer as a chain to success. It would be
clearer if all yellow boxes in the chain started with an action verb. In addition, the arrows do not
completely show how various actions flow (for example A.1.1. flows to A.2). Are not A.3.1 and A.3.2
sub categories of A.3.3?
Page 31. Logic chain. For Land Development, there is a flaw in the logic of the “How and Where”
intermediate result box of the logic chain if 9000 acres of additional forest is cleared for
development and local jurisdictions are still able to exceed GMA targets by 3%. We have less concern
about the .13% change in vegetated cover as it is within the range of annual natural regrowth and
within the error of repeated satellite-interpreted land cover estimates.
Page 41. Logic chain. This logic chain does not provide value to the document. There is no chain. We
suggest that one simplified chain be used for each strategy (which includes the substrategies as steps
in the chain).
Page 99, Target View: Wild Chinook Salmon. The second and third sentences in the first paragraph
need more context. It may be more appropriate to put the second and third sentences of the second
paragraph before the second and third sentences in the first paragraph to avoid creating a
misleading impression regarding the status of Chinook salmon.

The target view on dissolved oxygen in marine waters should include some additional strategies and
sub-strategies to address dissolved oxygen more comprehensively, including the following:

• Prevent or reduce nutrients from decentralized wastewater treatment, including reference to the
work by the Department of Health to develop and OSS nitrogen reduction technology.
• Address nitrogen from alder forests.
• Include mitigation strategies to identify ways to lessen the impacts of eutrophication.



General comments:

which is appropriate and critical to the overall effort. The views and diagrams demonstrate that
things are interconnected and complex but some may still find them confusing and difficult to follow.
The results chains help show potential linkage of actions to outcomes, but do not readily convey
which actions have the most impact on outcomes.
Specific comments:

stormwater management to groundwater. This is a significant consideration and should be
acknowledged, perhaps included in the science plan.

designations of Marine Recovery Areas to cover 90% of shoreline not primarily served by sewer. This
differs from current law that says MRA’s are those areas threatened or closed because of
contamination and the suspected contaminant source is failing septic systems. Does the Action
Agenda intend to suggest that 90% of shoreline not primarily served by sewer is threatened or
closed?
Page 13, goal 1, indicator swimming beaches

This calls for “All monitored Puget Sound beaches meet enterococcus standard.” It lays out key strategies
C11.3, C11.4 and C2.3 as the means to accomplish this. This needs to have a reality check. Wildlife, particularly
large flocks of birds, can easily cause exceedences of bacterial standards, and we really do not need to be
wasting time and effort to try to solve this in most cases. The 2020 indicator target summary could be changed
to: All monitored Puget Sound beaches do not exceed enterococcus standards from human causes. This issue
needs to also be acknowledged in the discussion about C11.3 and C11.4 on pages 262-264, and the discussion
about swimming beaches on pages 239-240. There is no mention in either of these locations of how natural
wildlife can also contribute to exceedences of bacterial standards. Where exceedences are likely to be caused
by wildlife, we should be able to avoid heroic efforts to try to track down and solve the non-problem.

Page 230, Target View: Dissolved Oxygen in Marine Waters The first paragraph says: “When levels of dissolved
oxygen get too low, fish and other animals may die, often in widespread “fish kills.” What is meant by
“widespread”? This seems to occur near the western shore in the southwest end of Hood Canal, and does not
appear to be “widespread”.

The second paragraph needs the following sentence at the end. The 2020 recovery dissolved oxygen target is
also the existing state water quality standard.

Page 231, Ecology’s Marine Water Condition Index: The explanation of the index is inadequate. All it says is it
combines measurements relevant to water quality. Furthermore, going to Ecology’s web site and looking it up
crashes and provides nothing. The Puget Sound Partnership site has a little more, but is also inadequate. At
least at the PSP web site it says that 12 different parameters are combined in the index. The web site doesn’t
say what these are but it does say that dissolved oxygen is important. There needs to be an explanation of what
the parameters are that go into the index, and how the summary numbers are generated. In color, it paints a
picture of terrible decline, with 1999-2001 being almost all green and 2009-2010 being almost all red. What
accounts for that change? Is it real or is it an artifact of the sampling? Each square is somehow summarizing 12
different parameters which in turn are measured over the year, with the number and timing of the observations
varying from year to year.
Healthy Native Species: The broader category of Forage Fish should be included not just isolating the
target on Pacific herring. Surf Smelt, Sand lance and Dungeness crab instars are important food
sources for juvenile salmon.


Section C, "Reduce and Control the Sources of Pollution to Puget Sound" encompasses all of the
actions in NOAA’s killer whale recovery plan to minimize pollution and chemical contaminants in
Southern Resident killer whale habitats and address oil spills. Although orcas are not listed as a
target for this section, the actions address two of the primary threats. A priority area for killer whale
recovery is increasing our knowledge of Polybrominated diphenyl ethers (PBDEs), PBDE inputs,
transport and bioaccumulation and minimizing effects on the whales. PBDEs are mentioned in the
introduction and the section covers a range of activities that would further this objective. Also, there
is a recovery target specific to PBDEs under the "Toxics in fish" indicator that will facilitate tracking
efforts to minimize PBDEs in Puget Sound. We recommend the Partnership focus control efforts on
specific bioaccumulative contaminants of concern, such as PBDEs, for top predators like killer whales.


The target views and results chain diagrams - Within our detailed comments, we point out instances
where the strategies, sub-stategies and Near Term Actions don't adequately align in a manner to
accomplish what is necessary to reach recovery targets. We strongly encourage PSP to conduct a
critical review of the relationship between the strategies and action and seek assistance from experts
in related fields and the Science Panel on the likelihood of reaching the targets based on the actions.
Recovery Target – Pacific herring
p.7 - Please add 2,000 tons of Port Gamble Bay herring stock to the recovery targets for Pacific
herring, along with the listed targets for Cherry Point and Squaxin Pass herring stocks. Port Gamble
Bay contains one of the largest herring spawning habitats in the Puget Sound, where herring stocks
averaged 2,176 tons between 1977 and 1997, but have declined significantly since that time. Port
Gamble Bay stock should be added to all sections of the Draft Action Agenda Update where the
recovery targets for herring are discussed.



Instream Flows. One of the Freshwater Protection targets is the “maintenance of stable and
increasing flows” in highly regulated rivers including the Skagit, Cedar, and Green rivers. Due to the
presence of large reservoirs on these systems, flows are already much more stable compared to
unregulated systems. Moreover, instream flow regulations and agreements on these rivers result in
minimum flows that typically exceed natural baseflow conditions. The list of target rivers on Page 90
does not correspond to the list of rivers shown in the graph on Page 91.

page 45 - Target View: Land Development (first paragraph)
Suggestion: Emphasize “working” forests within second sentence in this paragraph, namely “The
needs for homes, office buildings, stores, and agricultural lands to support our lives must be taken
into consideration as we strive to preserve working forests...”
The flow charts and diagrams within the Action Agenda are indecipherable. When you enlarge them
to size that should be legible, the text quality is distorted and unreadable. There are no comments
on these because no one could read them, so please don’t assume lack of comments on these means
readers agree with (or like) the diagrams. We hope to be able to review a legible version before the
AA is finalized.
Indicators and Recovery Targets

Swimming Beaches (pg 6)
Comment: Enteroccocus may not be the most appropriate indicator bacteria for swimming beach
health. It is used because it best mimics survivability of bacteria that has passed through PTOW, not
because it is the best indicator of human health risk. This would miss non-point contributions.

Wild Chinook (pg 7)
Comment: This should reference the Chinook recovery plan targets.

Shoreline Armoring (pg 8)
Comment: There should be an immediate ban on creosote piles and an incentive program for
replacement of existing piles with non-toxic alternatives. This should be decoupled from the
program to reduce armoring in order to reduce this toxic load as quickly as possible.

Freshwater Quality (pg 9)
Comment: There is a concern that these targets are being met by a reduction in ambient monitoring,
rather than by an improvement in water quality

Three 2020 recovery targets for Fresh Water Quality (pg 199):

Comment: These are subject to the same risk of manipulation of effort as the insects in small
streams; as currently written, the target could be met without fixing the problem- if we were to stop
monitoring all streams that <80, we would meet the ‘recovery target’. Should be re-written to state
that those streams that are currently <80, half of those will be >80.


A.7
Comment: No near term actions identified for A7.1, A7.2, A7.3, A7.4. If no NTAs are identified for
“Mitigation that Works”, then it must not be very important. If it’s not important, then why have it in
the Action Agenda?
Recommended Edit: Develop NTA's for sub-strategies A7.1 - A7.4.
Page 80
Please clarify throughout this section that the Mitigation that Works program applies specifically to
compensatory mitigation. Please add emphasis that improving compliance with SEPA mitigation
sequencing requirements is a prevention-based approach that is more effective that attempts at
restoration after the damage is done through compensatory mitigation projects. Also, in the first
paragraph on page 80, in the last sentence please change "low" to "high" mitigation failure rate.


Page 76. Implement and Maintain Freshwater and Upland Restoration Projects. (A.6). This section is
confusing because it stands alone from A.8. Protecting and Conserving Freshwater Resources.
Restoration projects require sufficient freshwater flows in streams and rivers to support salmon
during all critical life stages, and that dependence should be underscored in the Action Plan.
Page 79. Urban restoration (A6.3). This text should be improved to include at least a few sentences
about the huge amount of work currently occurring in urban areas. In addition to planting native
vegetation, there are efforts to remove invasive species, remove bulkheads/regrade banks, set aside
portions of private lots for open space, plant trees, and daylight creeks.
A.7 – The no net loss of ecosystem function section should evaluate the ecosystem changes that will
come with climate change.

A7 -- This section could be populated with relatively easily accomplished NTAs that could produce
more effective use of mitigation tools; for example, helping to achieve no net loss of aquatic
resources through permitting processes in local areas (e.g. King County, Hood Canal, etc.).

Page 82, 3rd line: delete repeated word “mitigation”.


We do not consider the In Lieu Fee Compensatory Mitigation program for the Hood Canal watershed
as only a pilot as described in the Action Agenda on page 82. The Hood Canal ILF is intended to be a
permanent tool available for our Hood Canal jurisdictions that allows for mitigation to occur, when
necessary, that supports recovery and restoration of the Hood Canal landscape. We expect the Final
Instrument for the program to be completed in June 2012 (not March 2012). The Action Agenda in
section A7.3 states there are no NTAs identified for compensatory mitigation tools. We believe,
however, that the NTA for the Hood Canal ILF program to be included in the Action Agenda update
should consider that once the Final Instrument is complete we will be working in earnest with our
partners, including the Puget Sound Partnership to apply the tools and assessments in the selection
of appropriate mitigation projects that meet the goals and objectives for the Hood Canal Action
Area.
Mitigation
We agree with the Partnership that broader, more strategic and well-designed mitigation is an
important element in the overall approach to Puget Sound recovery. We offer the following specific
suggestions to the mitigation section of the Action Agenda Update.

A7.1 Reinforce the importance of avoiding and minimizing impacts to resources,
particularly those with high ecological value and that are difficult to replace. Develop
and implement updated avoidance and minimization guidance consistent with the
ecosystem protection decision-making framework described in A1.2. We recommend the Partnership
emphasize that nothing in supporting increased, science-based mitigation should undermine existing
statutory requirements. For example, NOAA Fisheries will continue to consider mitigation sequencing
and avoidance of impacts when evaluating proposed actions under Section 7 of the Endangered
Species Act (ESA).

A7.2 Establish and implement a watershed-based approach to mitigation. This is an interesting
proposal and one we would like to explore with the Partnership. As this concept is developed we
recommend the Partnership consider how this proposal would work in places that are influenced by
conditions outside the watershed or that aren't directly linked to a watershed. Examples of such
places include estuarine and nearshore-marine locations in Puget Sound and some tidally-influenced
portions of lower rivers near the estuary.

A7.3 Support the development and piloting of innovative compensatory mitigation tools
including market-based techniques and other approaches.
• With 44% of the land base in incorporated cities and urban growth areas, there is little chance of
restoring hydrologic functions for aquatic invertebrates and therefore instream salmon populations
without setting aside large part of these areas to remain undeveloped. Coupled with the statement
that most residents prefer living outside these areas to have that “rural feel” and a rapidly growing
population, this planning region seems destined for unplanned sprawl which would be devastating to
Puget Sound’s water quality and living resources.
• Reference to Central basin is confusing since this no longer has geographic relevance in this action
agenda.
• Similar to Hood Canal Pacific Oyster, the statement of hatchery salmon to supplement tribal and
recreational harvest comes with no balancing acknowledgement as to the potential harm those
hatcheries are having on native stocks or wild Chinook recovery.
• Who is the North central/West Sound LIO? From which jurisdictions, tribes and organizations were
they made up or is there a list of participating individuals that can be shown to have any expertise?
Who invited membership and assembled the LIO?
• It is impossible for land cover changes to create no net loss of forest or hydrologic functions, no
matter how many “performance goals” are established unless the land cover changes are back to
native Central/West Puget Sound (page 326) - This area has made some progress, but it may need to
North forest.
meet more than four times per year. Addressing the near term actions with a results chain will help
clarify the intended results. Clear, measurable outcomes need to be defined along with leads for
actions and funding/ support strategies.
10.4.1
Comment: WAC incorrectly referenced.
Recommended Edit: The WAC 173-182 referenced is not correct….it should be WAC 173-183.

10.4.2
Comment: “ Support baseline scientific data collection for key species at risk in oil spills to enhance
assessments.” This NTA is extremely important ….but I am concerned it may not specific enough......
we would like to work with the partnership to provide more explanation on the rationale rework this
NTA if it looks like it is at risk of being lost during the upcoming prioritization process. I think we can
provide more detailed rationally and identify more specific performance measures.
Recommended Edit: Modify text: “ Support NRDAR planning and baseline scientific data collection
for key species at risk in oil spills to enhance assessments and recovery.

10.4.2 - Appendix D
Comment: WDFW not shown as owner.
Recommended Edit: WDFW should be identified as a primary owner/co-owner or as a secondary
owner of this NTA.

C.10
Comment: Environmental Restoration (or Recovery) should be included in the title strategy language
or it should be made clear in the narrative that responding to spills includes the natural resource
damage assessment and restoration process (NRDAR). Many of the key indicator species and
recovery targets could be adversely affected by a moderate to large sized oil spill in the Salish Sea.
We cannot avoid impacts from spills when they occur so it is imperative that we support
strengthening and improving our NRDAR planning tools, the use of best available science, and
collection of baseline data for key species and habitats to ensure that injured natural resources and
ecological services are fully restored following spills.
Recommended Edit: Add “Ensure recovery of injured natural resources and ecosystem services
impacted by oil spills.”

C.10 - On-going Programs
Page 251
We are glad to see oil spill prevention, preparedness and response included in the Action Agenda but
suggest an NTA should be included to secure full funding of Ecology’s program.


p.253 C10.2 - http://news.opb.org/article/nw-readiness-oil-spills-drops-risks-increase/ How are
current budget cuts going to be addressed in PSAA update? Are we going to continually ignore
economic reality in this document?
C10: Oil Spills
C10.1 NTA 1: “Assess trends in ship traffic, vessel incidents and incident notifications for use in
targeting ship inspections and setting standards evaluating spill risk reduction measures.

C10.1 NTA 2: Suggest modifying language: “Evaluate marine traffic risk assessment models that
could be used to develop appropriate oil spill risk reduction measures Evaluate existing Puget Sound
marine transportation oil spill risk assessments, identify any gaps in marine safety and work with
experts to develop appropriate risk reduction measures.” Note: This revised language would
strengthen and clarify this NTA however, additional funding is required.

C10.2 LNTA 1: The Strait Ecosystem Recovery Network (ERN) proposed changes to C10.2 LNTA 1
should be adopted and included in the Agenda. Specifically, we appreciate the Strait Ecosystem
Recovery Network (ERN) making oil spill prevention and response their third highest priority.
Ecology agrees with and supports the group’s 1/25/2012 document transmitted by John Cambalik.
We also greatly appreciate the Makah Tribe’s key participation in the Strait ERN and other processes
shaping regional and national policy on spill related issues. If so desired, Ecology would be happy to
assist in translating these excellent recommendations into measurable NTAs.

The Action Agenda in the San Juan Islands: Ecology supports the NTAs in this section of the Action
Agenda and appreciates the county’s interest in and attention to this important issue.

Add as a “Key Ongoing Program”: “Continue the Cross-Partnership Oil Spill Work Group as an
P. 252- 4 While some text has been added (p. 252-3) for BC (provincial and federal) being another
jurisdiction that needs to be involved with emergency preparedness, joint exercises that already exist
are not captured nor are opportunities for more collaboration identified. The experience with Exxon-
Valdez and the sage advice from the biologists involved with post-effect studies that a good baseline
can help with the legal issues, could be specifically highlighted (P. 254). The Action Agenda should
be encouraging joint work on a baseline throughout the area given the busy shipping channels.
Page 250. Oil spills (C10).
• The introduction fails to mention that the work group has not met since the establishment of
priorities in May, 2011. Also, this section lacks an education component, which is vital in reducing
spills and improving the speed of response. The workgroup is likely to meet in March – they have
been waiting for the BP study to be released, but they could also be picking part of the rule process
to weigh in on.
• The oil spill workgroup (and the Partnership's involvement in oil spills) is now set to expire in 2013.
We recommend that the Action Agenda include text that indicates that this responsibility and
structure should be made permanent.
• We recommend that the awkwardly written text in the sidebar entitled, “Local Strategies” be
replaced with something along the lines of, “Both the San Juan and Strait ERNs expressed strong
interest in their risk exposure to oil spills along the border with Canada. They have identified a
variety of near term actions associated with the ability to responds to spills quickly. This is timely
given the increasing volumes of tankers exporting “unconventional” tar sand oil from Canada
through the endangered Southern Resident Killer Whales’ core area of their critical habitat. State
and federal regulatory changes are underway associated with SB 1186 and the movement of the
High Volume Port Line (HVPL) from Port Angeles to Cape Flattery in July 2012 requiring attention.“
C10 Ongoing Programs (page 251) - Mention Ecology’s and EPA’s Spill Prevention Control and
Countermeasures Programs under the Clean Water Act. These rules address the bulk storage of oil
and the operator’s ability to prevent, prepare for and respond to oil spills that could reach navigable
water. These are on-going programs that are important and should continue.

Page 250. Oil spills (C10): The oil spill workgroup got off to a good start but has not met for some
time. However, the next meeting is likely to be in March 2012 since that is when the BP Vessel Traffic
Risk Assessment (VTRA) is scheduled to become publically available. In the meantime it is good to
have Todd Hass’s contribution to the rule process created by E2SB 1186 and interest in the VTRA.

We suggest that you replace the oddly written highlighted section entitled, “Local Strategies” with
for example: “Both the San Juan and Strait ERNs expressed strong interest in their risk exposure to oil
spills along the border with Canada. They have identified a variety of near term actions associated
with the ability to responds to spills quickly. This is timely given the increasing volumes of tankers
exporting “unconventional” tar sands oil from Canada through the endangered Southern Resident
Killer Whales’ core area of their critical habitat. State and federal regulatory changes are underway
associated with SB 1186 and the movement of the High Volume Port Line (HVPL) from Port Angeles
to Cape Flattery in July 2012 requiring attention.

Page 251. C10.1 Spill Prevention: Emphasize use of risk-based approaches to improve marine safety
and protect our environment, economy and quality of life. The long awaited state of the art Vessel
Traffic Risk Assessment for the Salish Sea required as part of the BP refinery dock expansion will be
released in March 2012. The two NTA’s identified in this section should both be directed in the
context of utilizing that model to address the identified questions.

C10.1 NTA 1: Assess trends in ship traffic, vessel incidents and incident notifications for use in
targeting inspections and setting standards.

C10.1 NTA 2: Evaluate marine traffic risk assessment models that could be used to develop
appropriate oil spill risk reduction measures.

Page 252. 0.1 LNTA 3: It would be odd to focus this forum on oil spill prevention efforts when federal
Page 250. Oil pills (C10). The oil spill workgroup got off to a good start but has not met for some
time. However, the next meeting is likely to be in March - for that is when the BP Vessel Traffic Risk
Assessment (VTRA) is to become publically available. In the mean time it is good to have Todd's
contribution to the rule process created by E2SB 1186 and his interest in the VTRA.

Replace section entitled, "Local Strategies" with, "Both the San Juan and Strait ERNs expressed
strong interest in their risk exposure to oil spills along the border with Canada. They have identified a
variety of near term actions associated with the ability to responds to spills quickly. This is timely
given the increasing volumes of tankers exporting "unconventional" tar sand oil from Canada. State
and federal regulatory changes are underway associated with SB 1186 and the movement of the
High Volume Port Line (HVPL) from Port Angeles to Cape Flattery in July 2012 requiring attention.

Page 251 . C10.1 Spill Prevention: Emphasize use of risk-based approaches to improve marine safety
and protect our environment, economy and quality of life. The long awaited state of the art Vessel
Traffic Risk Assessment for the Salish Sea required as part of the BP dock expansion will be released
in March 2012. The two NTA's identified in this section should both be directed in the context of
utilizing that model to address the identified questions.

C10.1 NTA 1: Assess trends in ship traffic, vessel incidents and incident notifications for use in
targeting in inspections and setting standards.

C10.1 NT A 2: Evaluate marine traffic risk assessment models that could be used to develop
appropriate oil spill risk reduction measures.

p. 253 C10.2.
Near Term Action: Northwest Straits Initiative will provide a model for coordinating and training
volunteers.

Near Term Action: Northwest Straits Initiative will hold HAZWOPER training in 7 counties.
These comments apply to the Biennial Science Work Plan and the Puget Sound Action Agenda.

Regarding oil spill preparedness, one missing technology is the use of realistic numerical models of
Puget Sound circulation to track - and predict the motion of - oil spills as they happen. We already
have working models, and it would take only a small investment to make them into tools that could
be used in real time by whichever responder needed them. This is similar to what NOAA does for
ocean oil spills, but NOAA does not currently support operational circulation modeling in Puget
Sound.


C.10.3: In addition to developing strategies to apply best available science and technology in the
event of an oil spill, resources should also be allocated to improve the existing body of scientific
knowledge on baseline conditions in areas at high-risk for oil spills. In this way, increased scientific
monitoring within these regions can help us better restore areas in the event of an oil spill. (p. 253)

Strategy C lists a number of NTAs related to oil spill response and readiness. We are concerned about
the impacts from potential oil spills and support these NTAs.
Prioritization:
According to the Executive Summary of the Agenda, Answering The Call To Action, the Partnership is
required, “to prioritize the actions required to restore Puget Sound.” Our reading and understanding
is the near-term actions identified in the draft Agenda are only an expression of new activities,
commonly referred to as the “change agenda.” What the draft Agenda does not represent is a
comprehensive assessment that includes the current ongoing activities around the Puget Sound.

While the Partnership has acknowledged its statutory requirement to prioritize actions for the
recovery of the Puget Sound, it is unclear why the Partnership did not first assess the ongoing
recovery and environmental enhancement activities before developing a new “change agenda.” This
is especially so because, in developing the Agenda, the Partnership was directed by the Legislature to
rely:
“largely upon local watershed groups, tribes, cities, counties, special purpose districts, and the
private sector, who are engaged in developing and implementing these programs,” (.260(1))

The Legislature further provided that:
“…participating groups should work to identify the applicable local plan elements, projects, and
programs, together with estimated budget, timelines, and proposed funding sources, that are
suitable for adoption into the action agenda. This may include a prioritization among plan elements,
projects, and programs.” (.260(4))
The clear statutory direction to the Partnership was to first assess and prioritize existing programs.

We would like to know when the Partnership plans to assess and prioritize the ongoing activities.
Will this work be done prior to implementation of the Agenda? Is there a plan to synthesize the
prioritized list of ongoing activities with the near-term actions?

Even as the Partnership moves forward with prioritizing the near-term actions, the draft framework
to evaluate the near-term actions is too complex, and will be absent broad public review and
comment.
The draft Agenda describes a two part process by which the Partnership will determine priorities
Priority Setting

The proposed response scales for the priority setting criteria are too detailed to readily evaluate the
criteria. We suggest using a scale of High, Medium, and Low to capture the relative values of each
criteria. We also suggest you request survey respondents include any relevant information used to
weigh the criteria or judge its potential effectiveness.

A clearer picture of relative priorities might emerge if it is possible to combine some of the proposed
criteria, and otherwise to minimize the total number of criteria to evaluate. We suggest combining
#3 Expected effectiveness of the action & #5 Extent this action prevents loss of key ecological
attributes of the main ecosystem component benefiting from the action. #9 Technical feasibility &
10 Readiness to implement, and perhaps eliminating #8 Relative cost, which could better be used to
evaluate implementation options. We also support the suggestions provided by the EPA in this
regard.

p. 15 Under the list of potential state legislative actions, there may need to be additional items,
including the action proposed under C7.1 NTA 2, regarding urban sanitary sewer service extensions
Concentrate remaining resources on developing a strategic focus.

We believe that immediately following this review of the Draft, our remaining resources and capacity
need to be dedicated to the task of prioritizing NTAs, and perhaps prioritizing strategies as suggested
in RCW 90.71.310. A well-developed and implemented prioritization process can extract a strategic
focus from the compilation of information in the Draft. We need to identify the most important
actions to achieve recovery, regardless of whether we know, or agree how we may be able to
implement these actions. The Ecosystem Coordination Board (ECB), a group designed to be a policy
advisory board, should not be relied on to reach consensus on a science-based prioritization
approach. Scientists should design and provide information on the scientific criteria. Policy makers
and managers (including ECB members) should respond to the policy and implementation criteria.

Do not prioritize ongoing programs, but do clarify your treatment of them.

The Draft states that the prioritization process presented for NTAs will also be used to prioritize
ongoing programs, starting with state programs. We do not support this approach for several
reasons. Prioritizing ongoing programs leads inevitably to an assumption that lower priorities are
unnecessary. The Department of Fish and Wildlife (Department) views our current Puget Sound
actions as being critical to achieve our recovery objectives. Some have suggested that the criteria
from the prioritization approach be used only to evaluate ongoing programs. In either case, as noted
The proposed approach to prioritization.
Current statute calls for the Action Agenda to be science-based, which DNR interprets to mean the
scientists’ best professional judgment as to the actions needed, and in what order, to achieve
recovery by 2020. DNR has indicated to PSP on numerous occasions that the prioritization of NTAs
must be science-based: scientists (most logically, the Science Panel) should be invited to evaluate
and rank NTAs on the basis of scientific criteria. Then, policy experts and technical staff together
should apply several non-science criteria to refine the ranking and begin the thinking on
implementation strategies for high-ranked NTAs. This is how the development of the Action Agenda
and the prioritization were described by the Partnership from 2007 until early 2011 at ECB,
Leadership Council, state caucus and other meetings and venues. Please clarify the rationale behind
changing to the prioritization approach now proposed.

Were the Action Agenda focused on the critical path and milestones to achieve the 2020 ecosystem
targets, the tension between “holding all the work” and showing priorities would be much reduced.
As it is, it is difficult to validly rank actions because one cannot see them within the context of the
critical path out to 2020. It is also difficult to rank actions because we have no real sense of what
actions have “moved the dial” in the past. This issue was highlighted by the Joint Legislative Audit
and Review Committee (JLARC) in its performance audit of PSP:

“Since, as noted above, the Partnership has not assessed progress restoring Puget Sound, it has little
information to make such funding recommendations or to confirm that no reallocation of funding is
needed.” [JLARC Proposed Final Report: Puget Sound Partnership Performance Audit, December 1,
2011, page 14.]
Proposed approach to prioritization. Generally, Ecology believes PSP proposes a framework that, if modified, can be sufficient
to provide a relative ranking of NTAs. While no prioritization process is perfect, the proposed process is a significant
improvement over the initial Action Agenda, which did not have a transparent, public process. Ecology’s specific comments on
the approach to prioritization include the following:
a) Given the subjectivity inherent in any prioritization process, we believe it critical to beta test the tool to determine its
relative accuracy. For example, a prioritization process that ranks stormwater management as a low priority would indicate a
flawed tool, based on the empirical evidence showing that pressure as the leading source of pollution to Puget Sound.
b) Clarifying how the prioritization process will work is critical. Simple addition of scores will not suffice, as a project that ranks
high on all criteria but is technically infeasible, should not result in a priority ranking. As proposed by PSP staff, priorities
should be set based on weighted scores. For example, more data driven criteria (e.g., cost, feasibility, ability to make an
environmental difference) should be worth more than those that are more ambiguous or subjective (e.g., public support,
equity).
c) Ecology supports PSP and EPA’s suggestion to simplify the response scale to “High, Medium and Low” and to eliminate the
percentage ratings. It would very difficult – likely impossible – to rate pressure reductions so specifically, which also would
provide a false sense of accuracy.
d) There has been considerable discussion about having “scientists” score the “scientific questions” and policy folk score the
remaining. While there is considerable subjectivity in such an exercise (i.e., difficult to parse out whether a question is pure
science or pure policy, scientists are not completely objective, etc.), Ecology sees value in have a more “scientific” group
respond to the more “science-based” questions and policy makers respond to the remaining questions. Ecology supports
asking the Independent Science Panel and a select group of scientists representing the broader interests of the Management
Conference to perform this task. Whether these processes happen sequentially or concurrently is of less import than being
able to parse out the “science” responses from those of policy makers. Providing transparency for this process will be of great
value to the prioritization discussion.
e) We understand that there have been requests for a single priority list of all NTAs. If PSP chooses to do this, we also
encourage PSP to have the ability to divide this list by strategy (A-D). That way, entities who believe a single prioritized list is
meaningless will also have access to more meaningful prioritized lists by strategy.
f) With regard to planning-based NTAs (i.e., “provides guidance”, “assesses”, “evaluates”, “identify”, “convene”,
“recommend”, “prioritize” etc), it is important to understand whether a reviewer bases the answer on the assumption that the
plan will be implemented (even though the NTA doesn’t state this). Or should every planning NTA be evaluated based solely
on the development of a plan (e.g. 0% environmental benefit for Question 1)?
g) In regards to the specific prioritization questions, we offer the following:
The prioritization approach is intended to evaluate proposed NTA for the Action Agenda. However
without clear linkages to Science Plan items and ongoing programs, the prioritization may not be
adequately informed. Science Plan items have already been vetted through a prioritization process. If
we can assume that results of the Science Plan are forthcoming, this could be used as a level of
screening or refinement for some near term actions. Currently, some NTAs seem very similar to some
Science Plan items. Although we suggest that duplication should be reduced, interdependencies and
extensions of work from the Science Plan to the Action Agenda and vice versa should be promoted.
Similarly, the value and relevance of some ongoing programs may increase due to specific NTAs and
the significance of such linkages should be factored into prioritization.

The areas of information proposed for the prioritization are too numerous. Consider focusing on
scope, effectiveness, geographic extent and implementation in an incremental way. If NTAs are
unrelated to recovery targets and are not expected to be effective, there is no need to consider the
geographic extent or implementation of the NTAs.
• Scope -- All NTAs should have a strong link to recovery targets. Consider revising criterion 2 to
reflect PSP's values in NTAs with high relevance to a single target vs weaker relevance to many
targets. A separate criterion should evaluate expected effectiveness. The rankings as currently
defined in the draft present a bit of a challenge. It is clear what would result in a more favourable
ranking. It is more difficult to sincerely attribute NTA toward percentages of progress toward a
target. Indeed, some of the Science Plan actions propose measuring the effectiveness of various
Page 25. Setting 2012 Near-Term Priorities
 • Among the priority pressures identified at question 1 (“Potential contribution to ecosystem restoration by reducing priority
pressures), we recommend the following critical component of recovery should be included: “loss of flows in streams and
rivers”.
 • We are encouraged by the Prioritization Framework that will be informed by some fact-finding for each NTA. We are
concerned about how these will be weighed against one another and would encourage emphasis be placed on reducing
pressures and preventing ecological loss.
 • We also strongly suggest adding a heavily-weighted climate component to this section that would help the Partnership
include climate as a cross-cutting issue at the NTA level. This is the only way to ensure that NTA's which specifically address
expected climate impacts are given priority. We recommend the following model (similar to the examples on Page 25)
Prioritization Criteria:
Potential to positively contribute to climate change preparedness:
Does the NTA Facilitate Adaptation?
1) Does the NTA protect adequate space?
The best defense against climate change is to protect large wild places and surrounding buffer areas which are connected to
other protected core areas. This connected wildlands network will allow imperiled species to move to more hospitable
habitats as the climate changes, thereby increasing their chances of survival. Historically, we drew up boundaries for proposed
protected areas based upon what met strict historic criteria for parks or wilderness areas, and we presumed the climate would
remain stable. Going forward, we need to design climate refugia that not only have core wilderness areas, but also provide for
restoration and connectivity and that look beyond federal public lands. A core area may be an existing protected park,
wilderness area, or refuge, or it may be an unprotected roadless area. It should be large, relatively wild, and largely
unfragmented. A buffer area is adjacent to a core area and is generally less wild, but still largely undeveloped. Sometimes it
may have been developed in the past but now it is in the process of restoration. A connecting corridor may be a continuous
pathway between nearby core areas, or it may be a series of stepping stones that allow connectivity. An example of how this is
changing our work: now when we lobby or litigate to protect endangered species critical habitat, we also make the case that
the designated habitat needs to take climate change and range shifts into consideration. Protecting adequate space represents
a serious challenge around Puget Sound, and must be prioritized where it can be.
2) Does the NTA limit the relevant non-climate stressors that adversely impact threatened species?
NTA Prioritization
The NTA prioritization process is still under development and the draft Action Agenda only addresses the first two steps
culminating in information gathering. The current public review of the draft Action Agenda update will result in comments
directed at both the proposed NTAs and the prioritization process. As such, it would be inappropriate to significantly advance
the prioritization process for NTAs prior to reviewing and incorporating the input from the public comment period. We
understand that there is considerable upfront design and preparation work, but implementing the prioritization process itself
needs the benefit of the input that has been requested through the review process. We support the use of the Ecosystem
Coordination Board (ECB) workgroup in completing the NTA prioritization process and strongly recommend that the full
process for identifying priorities be mapped out and explained prior to undertaking the initial steps. This is important because
how the initial steps are implemented, including gathering and documenting associated information, is likely to be influenced
by later steps that vet, provide transparent explanation or concur with earlier information inputs. Similarly, the process(es)
that will be used for setting ongoing program priorities or honing local priority lists need(s) to be explained.

The proposed process does not reference any published prioritization approaches that are being used in other ecosystem
protection and restoration initiatives. PSP should look closely at the published literature for examples of prioritization
methods/processes in other ecosystem restoration/protection efforts that might be expanded or adapted to Puget Sound.
Based on a cursory review of other published prioritization methodologies, it appears that the Partnership’s proposed
approach has some criteria for which the data are poorly characterized. For example, we believe that the public support (#11)
and equity (#12) criteria should be eliminated because the type of data available may be too poorly characterized to be used in
a prioritization. Criteria with robust information should be used in order to produce replicable and consistent results. It also
appears that other prioritization methods limited the number of criteria to those that were most important to the outcomes
being sought and that could be easily supported with consistent and available data. In this way, the complexity of the process
is reduced, while acknowledging the uncertainties inherent in the prioritization. PSP may wish to ask the Science Panel to
form a working group to quickly further develop the criteria. EPA is proposing that the following criteria be eliminated or
combined:

Criterion 1: This information is redundant with the considerations involved in criterion 2. Further, the five pressures listed are
not comprehensive. We recommend this criterion be deleted.
Criterion 2: We recommend keeping this criterion; however, the ranking should provide additional value for those NTAs
addressing more than one target (we assume the NTA score involves averaging the ranking across the (up to five) targets it
addresses).
Criterion 3: We recommend this criterion be integrated with Criterion 5 because effectiveness should be judged relative to the
ecological endpoint.
Criteria 4: We recommend this criterion be kept but that the ranking factors provide a greater rating for high, local impact
NTAs, as well as geographically extensive projects.
Criterion 5: see Criterion 3
Criterion 6: We recommend keeping this criterion but including Criterion 7 as a subfactor within it, since economic health
The Action Agenda Update presents over 150 NTAs. We suspect that the number will grow as a
result of this review and comment period. Given the scale and extent of the NTAs, there is still a
need to refine and prioritize the actions to match available funding, capacity, knowledge and skills.
We want to understand how the prioritization of actions will be developed? Through the
development of this current update to the Action Agenda, we hope to work with Partnership staff to
see how the regional strategies and NTAs for all of Puget Sound can be integrated with and support
local priorities and strategies. We also expect that funding of eventual actions will result from a
competitive process that considers local priorities.
The proposed prioritization process should not detract from focusing on critical actions: We
appreciate the work the PSP has done to develop a process that is transparent and replicable and
meets the mandate to prioritize NTAs. However, we are concerned that a survey approach, even
through the structured process that you describe, may prove difficult to administer and not answer
key questions about how we should focus our resources across Puget Sound and sequence actions
(please see Attachment 2, an e-mail sent to Gerry O’Keefe from Fred Jarrett on 11-7-11). We also
continue to be concerned about how the prioritization process will consider existing water quality
mandates, such as stormwater permits, combined sewer overflow (CSO) controls, and Superfund
cleanup.
- We support the goals of the prioritization process to be “explicitly information based, transparent
and replicable.” We remain concerned about whether or not the process can be effectively
implemented, with over 200 NTAs, and multiple parties participating. As indicated above, it may be
preferable, in addition to (or in lieu of) prioritizing the 200 or so actions, to identify a much shorter
list of significant legislative, policy, or funding actions that would have the most impact toward
restoring Puget Sound (toward meeting the recovery targets). The current NTA list contains so many
actions, many of which are not funded. This makes it difficult to understand which are truly
priorities, and also implies that many of the listed NTAs are likely to occur (when the reality is that
We are concerned that the criteria being proposed for near-term prioritization can not be effectively
applied. What are the five (5) areas that PSP is recommending local government consider? These
may need to be broken down into urban and rural and nearshore and stream environments These
need to be realistic – within our authority and existing funding capacities, unless additional outside
State or Local funds are made available.

Research Vs Action: The document only calls out research and monitoring and indicates
prioritization of actions is a future task. This just delays action. Start with the previous work that the
WIRAs have listed as priorities and recognize what has been done. Then using the analysis of high
benefit, adjust the priorities to make sure the greatest gain is achieved no matter the location. This
will not keep our proactive local governments from making further contributions as we still
appreciate their small runs.




Proposed Approach to Prioritizing
We believe prioritizing actions, programs, plans, discrete construction or acquisition projects
altogether against each other to generate a single list is impossible and a significant waste of
resources. That said, we see the logic in using the open standards process, as proposed by the
Partnership. However, we are unprepared to commend until we see how the process will be applied
in the Action Agenda.

Notwithstanding the success or failure of the Partnership’s proposed prioritization process, overall,
we encourage the Partnership to link, with scientific justification, actions to environmental indicators
and targets. Furthermore, we believe that doing so will aid allocating the amount and/or percent of
responsibility for target attainment to various Action Areas. Since many of the ecosystem targets
adopted by the Partnership are not equally characteristic and thus, distributed throughout the
Sound, that regional variability must be accounted for in any prioritization system. Doing so will
respond to the reservations and uncertainties of whom the burden falls upon. A regional cost
benefit calculation of “ecosystem targets” needed for recovery is important as well, so that policy
makers and burden-carriers understand what they are paying for with the costs they incur. Finally,
linking a prioritization method to the ecosystem targets links outputs (actions) with intended
Prioritization Process for the Action Agenda

The Partnership is required to prioritize the actions required to restore Puget Sound. This is a
daunting task, but we understand that the prioritization process will begin soon and is planned to be
completed during spring 2012. We request that the PNPTC and our member tribes be informed and
included in the prioritization process in a timely manner so we can effectively participate and
contribute to this important process.




The PSAA & BSW identifies a large number of Near Term Action (NTA) items, which have not been
prioritized. Our understanding is that the prioritization process will occur following the close of the
comment period. We believe that prioritization is needed now to reduce the number of NTAs to a
more manageable and achievable number. Therefore, we request that the plan be circulated again
for public comment following the prioritization phase. We also suggest that the NTA list include a
column that consistently identifies the agencies/parties responsible for implementing each of the
NTAs. This would benefit local governments as one of the primary implementing parties.




Prioritization. While perhaps easier said than done, it would have been helpful if the prioritization
process of the Near Term Actions (NTA) would have happened earlier and incorporated into the draft
Action Agenda. This would have given us and other interested parties the opportunity to react the
actions the Partnership expects to undertake in the near future. While the lists of near-term actions
include numerous worthwhile proposals, projects and programs, it is difficult to tell which are
happening, which will be acted on (and by whom), which are funded or lacking funding and which
actions we simply hope to be able to undertake sometime in the future. We know, for example, that
many of the NTA are not new, but rather have not occurred or are occurring slowly due to ongoing
lack of resources. The NTA should also be consistent. If the decision is not to integrate local
priorities, then the list should only reflect those that are Sound-wide or comprehensive.

An important if tangential point; our staff commented time and again that they feel strongly that
updating the Action Agenda every two years makes no scientific or practical sense. This two year
timeline necessitates that the limited Partnership staff continually focus on updates, when the
critical mission needs to be assuring implementation of priority actions. Water system plans, for
example, are required to be updated every six years, a much more rational amount of time. We
suggest that the Partnership statute be amended to allow for time to focus on action rather than on
Step 1, Creating the Prioritization Framework
General Comment: Working with our Strait Action Area representative (and alternate) to the
Ecosystem Coordination Board, how best can the Strait ERN LIO provide effective and timely input
during the development
of the Prioritization Framework?




PRIORITIZATION PROCESS
The proposed revisions to the Action Agenda indicate the Partnership will be prioritizing the actions
in the final document. We support the notion of prioritization but there is very little information in
the proposed Action Agenda materials to give an indication of what will be the prioritization process.
One possibility that has been discussed is the Partnership would first prioritize near-term actions and
then prioritize ongoing actions. We would strongly recommend the Partnership reverse this
approach and prioritize ongoing programs first.

In revising the existing Action Agenda, the Partnership is fundamentally asking the questions: What
did we say we would do? What did we do? Did it work? These questions necessarily require us to
look at ongoing programs first. To do otherwise, to look at proposed new actions first, would be to
essentially start over from scratch. By evaluating ongoing programs first in the context of whether
these programs are or could help address threats to Puget Sound would serve a number of
important values, including honoring existing work, working within existing limited resources but
adjusting to me more effective, and establishing a true adaptive management approach to revising
the Action Agenda in the future.

The following are individual comments added to the form emails submitted via Sierra Club. See "Via
Sierra Club" link under public comments for a list of who said what.

1. Please add "climate disruption" to the Prioritization Framework of the Puget Action Agenda.

2. The most important thing that the Puget Sound Partnership can do for the health of the Sound is
to prioritize actions that limit global warming. Increased CO2 and other global warming gasses in the
atmosphere will cause increased oceans acidification and other climate change effects that will be
disastrous for the health of the Sound.

35. As long-time members of People for Puget Sound we fully support action to prioritize restoration
and protection strategies with consideration for climate change.

36. As long-time members of People for Puget Sound we fully support action to prioritize restoration
and protection strategies with consideration for climate change.
B.5.1.
Comment: New NTA needed
Recommended Edit: B5.1.1: Evaluate opportunities for public access compatible with protection
objectives for sites acquired with public funds for conservation purposes. Prioritize shoreline public
access funding at these sites.Performance metric: Public access consistent with protection objectives
is implemented at 100% (?) of sites acquired with public conservation funding

Page 145. Improving Public Access to Puget Sound (B5.1).
• The maps that have been produced to date showing current types and amounts of public access in
the Sound should be mentioned in this strategy’s text and should be compiled and put on the
Partnership’s wiki. Trust for Public Lands has had extensive analysis completed to map and evaluate
public access across the entire Sound and this is available through their Puget Sound Greenprint.
Ecology’s Oil Spill response office commissioned the public access data to be developed for planning
purposes but it serves well as a public access/recreation map too.
• A key next step would be to prioritize gaps and identify opportunities for increasing public access,
based on those maps.
• In addition, the text is focused on public access to the marine shoreline but a similar need exists in
freshwater lakes, creeks and rivers.
• A caveat should be included in the text that public access should occur in a way that does not
cause environmental harm.
• We also recommend that we invest in the preservation and repair of public access and interpretive
facilities throughout Puget Sound such as parks, nature centers, public fishing piers, ADA accessible
trails, Washington Water Trails Association sites, etc. Underwriting free parking at public access sites
should be considered so that access to Puget Sound shorelines does not become a luxury to those
who can afford Discover Passes.
• One idea would be to, where appropriate, require that all state granted shoreline acquisition
projects include a public access plan and allow funds to pay for those elements within existing grant
programs that currently require those elements to be paid for by matching contributions.
B.5 (page 145) - This section could include a discussion of “ongoing programs” such as Ecology’s
coastal atlas and public access plan portions of SMP updates. Connect these actions to outreach and
education activities.

B5.1 – An NTA could involve asking restoration or acquisition project sponsors to add public access to
their projects where appropriate and not environmentally damaging.

B5.2 – It is not clear how this action is substantially different from B5.1.
B5:
- It would be incredibly helpful to incorporate a visual conveying the current state of public access to
the Puget Sound. At this point, it is difficult to understand how accessible shorelines are and the
degree to which access needs to be improved. (p. 145)
- This target view about estuaries, the recovery targets, and the logic chain do not fit within the
strategy relating to Public Access. This Target View would be better suited elsewhere within the
document. (p. 146-47)

B.5.1: This strategy is currently being addressed through a variety of state/federal coastal acquisition
and restoration grant programs.
A.9
Comment: “Protect and Recover Salmon” needs to be updated to include more information about
Steelhead, as this is the section where two near term actions, A9.2, 1 & 2, are called out.
Recommended Edit: Update "The Challenge" to reference steelhead.

A.9.2.2
Comment: WDFW’s Statewide Steelhead Management Plan has a strategy “Establish Network of
Wild Stock Gene Banks” for achieving natural production goals. This NTA may be related that, but it
is unclear. If so, and the fact that WDFW is “owner”, the language of the NTA should be modified to
reflect the agency’s current intent.
Recommended Edit: Modify language of NTA to reflect WDFW's current intent regarding Network of
Wild Stock Gene Banks, or clarify another purpose for discussion with the Department. Bob Leland is
the Department lead.
The habitat issues of the salmon restoration plans are based mostly on the unspoken premise that
“We will help salmon by using other people’s money to build habitat projects on the sites of willing
landowners.” This apparently was the best habitat enhancement effort that could be accomplished
by consensus, but it causes all the plans to avoid demanding that landowners must stop hurting
salmon. Although intense evaluation of the salmon plans apparently must await the 10-year point,
there are already substantial indications that the plans are failing. The tribal request to the President
that the federal government take over salmon restoration responsibilities from local authorities is
one of the indications that demonstrate the severity of the developing failure


Protect and Recover Salmon. The challenge should acknowledge work already done on temperature
projections with respect to salmon habitat requirements and encourage recovery plans to include
climate changes. A figure is included to illustrate this:

Habitat resiliency to climate change will be important in salmon recovery and should be considered
in setting priorities.

*See page 3 of EPA comments to view figure
• We recognize the improved integration of the Puget Sound Chinook Recovery Plan into the overall
action strategies, and that cross-cutting issues between salmon recovery and overall Puget Sound
recovery have been clarified since the original Action Agenda was released.
• Strategy A9.3, “Maintain and enhance the community infrastructure that supports salmon
recovery,” indicates that the near term focus will be on implementing ongoing programs (pg. 98).
Based on the Tribal White Paper and NOAA’s Five Year Review of Implementation of the Puget Sound
Chinook Recovery Plan, existing programs have been inadequate to protect habitat for salmon and
much more needs to be done. The Puget Sound Salmon Recovery Council’s current efforts to
identify NTAs that the federal, state and local partners will do to improve habitat protection should
be added here as a NTA.
• There are no specific NTAs identified for salmon recovery (on pg. 96 and 98). At a minimum, this
section should reference that the existing salmon plans all identify priorities for salmon recovery and
that the highest priorities for each action area should be pursued. Many of the NTAs in other
sections do relate to salmon, and these NTAs should be referenced in this section.
We understand that Salmon Recovery will be a major focus. Would the Sound be better served by
identifying the “highest priority salmon recovery projects,” e.g. culvert and fish-passage-barrier
removals in the near term? This is a focused, achievable priority that gets results, provides visibility
of success, and creates jobs.
Along with other tribes, we do not feel that the Action Agenda adequately identifies the measures
required to protect our Schelangen or way of life. There should be more emphasis on habitat
protections required for salmon recovery as salmon are an essential part of our Schelangen. The
Action Agenda should align state and federal programs to be consistent with the protection of treaty
reserved rights, salmon recovery and the required water quality and quantity. Lummi would rank all
actions on how soon and how much they would provide the ecosystem goods and services to
support the habitat required to produce harvestable salmon populations. History has demonstrated
that loss of forest cover, channel simplification, flood plain development, disruption of the natural
flow of water, estuary simplification, and change in water quality as the result of human activities are
all associated with the decline of salmon stocks which depend on these services and a healthy and
productive food chain to survive.
~Salmon recovery actions appear to be less central to our priorities than they should be. Salmon are
critical culturally, legally and ecologically. They are both a keystone and indicator species within
both the freshwater and marine realm of Puget Sound. If we do what is needed to recover salmon,
we will be most of the way to Puget Sound ecosystem recovery. Further, much of the existing
attention, funding and effort of partners and stakeholders is focused on salmon recovery in Puget
Sound. The structure and content of salmon recovery actions in the Update leaves the impression
that it is separate from the larger cause of salmon recovery. This undermines the efforts to integrate
the multiple aspects of recovery and achieve the efficiencies and impact needed to attain recovery.

~Make the centrality of salmon recovery efforts clear. First, the salmon strategies section should be
at least as robust as the other strategy sections – even if these individual chapters are moved to the
appendix as suggested above. Second, clarify that land protection, floodplain and estuary
restoration, water quality and other such strategies should be geared, in part, to protecting and
restoring the habitat that salmon strategies and actions not listed elsewhere in the Action Agenda.
A9.2 Implement salmon recovery depend on. Third, consider making salmon recovery the first
 -Habitat, harvest and hatchery action integration: NOAA Fisheries recognizes the need to integrate
recovery actions across habitat, harvest and hatchery disciplines. Our 2006 Supplement to the Puget
Sound Chinook Salmon Recovery Plan noted that coherent integration of activities across the “Hs” is
necessary to enhance salmon recovery effectiveness. H-integration remains a challenging issue. We
support the Partnership, Recovery Implementation Technical Team, watershed technical teams and
others trying to develop an H-integration approach. Our staff will provide input and guidance on H-
integration as this sub-strategy develops.

 -Monitoring and adaptive management: We agree that monitoring for population status, and
compliance and effectiveness of recovery actions are necessary, and have staff dedicated to the
effort. Further, we agree that watershed-level adaptive management plans remain important gaps
for Puget Sound Chinook salmon recovery.

We do not believe a “significant gap in our understanding of how landscape changes impact our
ability to recover salmon” substantially impairs salmon recovery. There is a growing body of scientific
research linking watershed conditions to human development and climate change. Watershed
groups leading recovery of salmon habitat will benefit from this emerging science. In addition, results
from Puget Sound’s Intensively Monitored Watersheds will inform watershed- scale actions. Recent
reviews, including an investigation done by NOAA in 2011, identify a failure to implement recovery
actions, rather than a lack of scientific understanding, as the impediment to salmon recovery
progress.
The Action Agenda must serve to align programs with salmon recovery

We have consistently reiterated through the TRAR initiative and subsequent follow up that state and
federal programs must be aligned with salmon recovery. One way the Action Agenda can support
such alignment is to ensure that funding associated with the Action Agenda is conditioned to achieve
consistency with protecting treaty rights, salmon recovery plan habitat objectives and state water
quality standards. While we realize that PSP is still developing a funding strategy for the Action
Agenda, it is unclear how the current document will guide achievement of these principles.
Therefore, we believe that PSP must amend the document accordingly to reflect a funding strategy
which accomplishes these goals, including a monitoring plan and response timelines.

As you are aware, the Action Agenda serves as the Comprehensive Conservation and Management
Plan (CCMP) in accordance with § 320 of the federal Clean Water Act. As a matter of law, Funds
granted under this act are solely appropriated for the purpose of the development and
implementation of the CCMP. Therefore, the Action Agenda, i.e. CCMP, serves as the guiding
document to determine eligibility for the expenditure of federal National Estuary Protection Funds
(NEP) – a primary funding source for Puget Sound activities.

To ensure that the Action Agenda can serve to guide alignment of programs with salmon recovery, it
must explicitly provide that funding be conditioned such that publicly funded projects will deliver
results that are consistent with state water quality standards and individual watershed recovery plan
objectives. NEP funds which support the implementation of best management practices must
ensure that the practices implemented are consistent with state standards and the objectives of
individual recovery plans.

Thank you for the opportunity to comment on the draft Action Agenda Update. At our meeting on
January 26, 2012, the Puget Sound Salmon Recovery Council (Council) discussed the draft document.
This letter provides you with initial input from the Council as a whole; member organizations intend
to submit detailed comments.
The Council supports the idea of identifying strategic initiatives in the draft Action Agenda Update, to
assist the Puget Sound Partnership (Partnership) with targeting its efforts. We
understand that these strategic initiatives are still under development.
The Puget Sound Salmon Recovery Council strongly urges you to include implementing the Puget
Sound Chinook Salmon Recovery Plan (Recovery Plan) as a strategic initiative in the
2012 Action Agenda. We believe this is wise for several reasons:
- Salmon recovery is Puget Sound recovery. The two are intertwined.
- The Recovery Plan is a regional plan based firmly in science. It contains chapters for restoring each
watershed in Puget Sound, plus the nearshore, to health. Scientists vetted the Recovery Plan, and
the National Oceanic and Atmospheric Administration adopted it.
- Communities throughout the region are actively participating in implementing the Recovery Plan.
- In short, we believe that including implementing the Recovery Plan as a strategic initiative will help
the Partnership achieve its goals efficiently and effectively, and carry out its responsibility to
implement the Recovery Plan.
I also recommend an approach to salmon recovery in Puget Sound that is more clearly tied to
existing efforts. As you know, the National Oceanic and Atmospheric Administration (NOAA) has an
approved plan for recovering Puget Sound Chinook salmon. The plan was approved in 2006 and is a
product of significant stakeholder investment and input. The Recovery Plan identifies limiting factors
and strategies for addressing those factors. This plan is supported by Three Year Work Plans
developed at a watershed-by-watershed level. It is widely supported and used as the leading
strategy for Puget Sound Chinook recovery. While the draft Action Agenda has the broader purpose
of recovering the Puget Sound ecosystem overall, I believe following the NOAA plan can only benefit
that broader purpose. I think that deviating from using the NOAA plan as the lead strategy for Puget
Sound Chinook recovery will likely create confusion. Therefore, rather than incorporate the NOAA
plan into the draft Action Agenda, I recommend that the draft Action Agenda defer to the NOAA plan
for its strategy on Puget Sound Chinook recovery. Additionally, while we do not yet have an adopted
Steelhead Recovery Plan, I encourage you to identify and begin to take the actions necessary to
advance the recovery of steelhead.

A9.1: Including this as a strategy when it simply restates previously mentioned strategies and goals of
the Action Agenda seems redundant. It is already discussed in the introduction to salmon recovery
that many of the strategies listed in A-D are critical for salmon recovery. Emphasis should be given
to the connection of ecosystem health, both marine and freshwater, and salmon recovery in the
introduction of this section, rather than stating it as a strategy goal. (p. 95)
A9.2: NTA’s relate only to steelhead, but there are no near-term actions explicitly addressing the
other elements of the salmon recovery strategy. Does this mean that they are ongoing programs at
this point or that they will not be addressed in the next few years? Please clarify or add near term
actions to address additional elements of the salmon recovery strategy. (p. 96-97)
A9.3: It is unclear who will be responsible or how the entities listed in A9.3 are going to be organized
around salmon recovery. We request greater detail be added to this section to make it more
cohesive and comprehensive. Include in this sub-strategy how the partnership plans to support the
entities involve, in light of poor funding. (p. 97)

Salmon/Listed Fish Recovery. One of the major challenges to protecting and recovering salmon
identified in the Action Agenda is under-investment in capital projects. The document should stress
that one of the greatest challenge at this time is funding, developing the engineering and
administrative capacity, and gaining political support for large public works projects that are needed
to remove or modify existing infrastructure including dikes, levees, jetties, sea walls, riprap, and
roads that exist along the shorelines, estuaries, deltas, and major rivers of the Puget Sound. The
projects can cost millions of dollars each, but are essential to restoring the habitat and ecological
processes required to achieve salmon recovery. Most salmon restoration efforts to date have
focused on relatively small projects that are spread over the Puget Sound landscape, as identified in
Salmon Plans. Large estuary projects completed in the Nisqually and Skagit deltas in recent years
provide examples of the types of large projects needed for salmon recovery in the future.

The Puget Sound Salmon Recovery Plan was developed to guide the recovery of three ESA-listed fish
species: Chinook salmon, Hood Canal chum salmon, and bull trout. The PSP continues to work
closely with NOAA Fisheries for implementing the recovery of Chinook and chum salmon. However,
working with the USFWS to guide the recovery of one of the three ESA-listed fish species in the Puget
Sound is barely mentioned. Indeed, the USFWS is only mentioned under the “other federal” agency”
agency in Action Agenda. The PSP should add the following near-term action: “The USFWS will
finalize the Bull Trout Recovery Plan for the Puget Sound Distinct Population Segment (DPS) in 2012.
The PSP will work with the USFWS and the Puget Sound Bull Trout Recovery Unit Team (RUT) to
implement the recovery actions identified in this plan.”
Near-term action should be to fully implement the existing Chinook Recovery Plans


A9 Protect and recover salmon.

There is an effective system currently in place on the local level for salmon recovery. The Lead Entity
program implements and manages the salmon recovery plans for each watershed. The funding for
the Lead Entity program should be maintained and local salmon recovery plans should be funded
and implemented at a level able to meet the 10 and 50 year goals. Current funding levels are only
about 25% of what is actually needed to stay on pace to meet our targets, and we are falling behind
every year. Combined with the increases in population and the associated development pressures,
the lack of funding will only become more acute with time as land costs increase. The Stillaguamish
Tribe requests that the Partnership include the implementation of the Puget Sound Chinook Salmon
Recovery Plan, the recovery plans for each WRIA, and the three year work plans as a strategy.



The Tribe is concerned that The Skagit Chinook Recovery Plan's local focus and watershed specific
data are muddled within the Action Agenda's focus on Puget Sound Health. These Chinook Plans
were developed, reviewed and accepted at both the state and federal levels, yet implementation of
these actions have not met expected timeframes for implementation. Significant funding was
identified to restore the habitat that supports this iconic species, yet funding for these efforts has
fallen short of expectations. Additionally budgetary constraints have also limited the manpower
available for carrying this work forward. Now the Tribes are also faced with addressing the new ESA
listing of Puget Sound Steelhead, yet funding has not been secured to implement the recovery plans
for the Chinook listings. The focus on recovery of listed ESA species has also restricted the ability to
implement projects that benefit non-listed salmonids, even though these Treaty resources are
important for Tribal cultural identity. Some of the near term actions are intended to protect listed
salmon recovery. Yet to the Tribe all salmonids are part of this responsibility, which will sustain the
health of Puget Sound and its citizens.

Full goal (A9) to protect and recover Salmon is mutually supported by the Tribe. these programs also
The Document - Pg. 98: Funding sources textbox: The state funding provided byThe three year work
serves as match funding for federal grant programs such as NOAA's Coastal and Estuarine Land
Conservation Program, FWS's North American Wetland Conservation Act Grant Program, National
Coastal Wetlands Conservation Grant Program, and the Cooperative Endangered Species Fund Grant
Programs. These national programs support the goals of the Action Agenda through conservation
and protection of coastal nearshore habitat and terrestrial upland habitat, and provide increased
habitat for federal and state T &E species.
A9.2 Implement salmon recovery strategies and actions not listed elsewhere in the Action Agenda.
Actions in the salmon recovery plans that are not incorporated elsewhere in the Action Agenda are
listed below.
A) Harvest management: Brief description of Harvest Management Plan to be added to final Action
Agenda.
WFC recently analyzed data supplied to us by the Pacific Salmon Commission and have determined
that a significant number of Puget Sound Chinook are harvested in “mixed-stock fisheries.” [“the
marine areas in the Pacific Ocean, Strait of Juan de Fuca and Puget Sound through which salmon
originating from different river systems migrate on their way to their natal stream. Many species and
populations may be mixed together in these areas.” Shared Strategy, page 100. These fisheries are
not selective in that both wild Chinook and hatchery-origin Chinook are killed.] Those fisheries are
governed by the Pacific Salmon Treaty and not through the Harvest Management Plan mentioned in
A9.2.A. Certainly some of the Puget Sound fish killed in the mixed-stock fisheries are wild Chinook
listed under the ESA. Although the Treaty has undergone the Section 7 ESA consultation process,
that exercise merely avoids “jeopardy” and likely does not consider what is best for recovery of the
Section A9 Protect and Recovery Salmon, p. 92. It Southern Resident Killer Whale need to actions
Puget Sound ecosystem. In addition, the needs of is concerning that no specific near-term be taken
have been identified for salmon recovery (on p. 96 and p. 98). At a minimum, this section should
reference that the existing salmon plans all identify priorities in salmon recovery and that the highest
priorities for in each action area should be pursued. Many of the near term actions in other sections
do relate to salmon. These near term actions should be referenced in this section to avoid the
impression that there is a lack of urgency for near term action for salmon recovery.

In section A9-3, “Maintain and enhance the community infrastructure that supports salmon
recovery” says that the near term focus will be on implementing ongoing programs (p. 98). Based on
the Tribal White Paper and NOAA’s Five Year Review of Implementation of the Puget Sound Chinook
Recovery Plan, existing programs have been inadequate to protect habitat for salmon and much
more needs to be done. The Puget Sound Salmon Recovery Council’s current efforts to identify near-
term actions that the federal, state and local partners will do to improve habitat protection should
be added here as a near term action.

A key missing category under the list of Action Agenda Strategy Categories with a Strong Salmon
Recovery Nexus on p. 94 is C1 Reduce the Sources of Toxic Chemicals entering Puget Sound.
The update, however, falls short in showing a clear path to achieve salmon recovery in our and other
watersheds. We suggest that the Update acknowledge that salmon recovery in Puget Sound is a
watershed initiative, and that the Action Agenda treat salmon recovery as such. For salmon recovery
to be successful, the actions necessary to recover salmon population must foster watershed-scale
implementation. The Action Agenda must support implementing the Puget Sound Salmon Recovery
Plan which embodies the highest priority actions that have been agreed upon by federal, state, and
local governments and many stakeholders that have been working across jurisdictional boundaries in
our watersheds to bring watersheds back to health. We believe that healthy watersheds are
necessary for a healthy Puget Sound. Implementing watershed priority actions to recover salmon
would be a major step toward Puget Sound recovery. Implementing the watershed-based salmon
recovery plan that we prepared for WRIA 9, for example, will achieve the following multiple
ecosystem objectives to recover Puget Sound:
• Clean up stormwater through regional stormwater retrofits
• Clean up toxics and improve estuarine habitat
• Restore and protect beach feeding processes
• Reconnect the river to its floodplain
• Re-establish historic fish passage to over 45% of the watershed area
• Recover threatened species, prevent extinction of species, and avoid future listings
These objectives will not be achieved through individual actions of individual agencies and
governments. A watershed-based governance structure and funding strategy for identifying,
prioritizing, implementing, and adaptively managing the diverse watersheds of Puget Sound needs to
be a priority action for Puget Sound recovery and complement the overall Puget Sound recovery
funding strategy.

Moreover, to demonstrate a strong commitment to protecting and restoring Puget Sound we
strongly recommend that the Update explicitly include:
Local Action Agenda in the San Juan Islands (page 337) We are encouraged to see recognition of the
influence of the Fraser River in BC on waters in San Juan County. Also encouraging is recognition on
the need to work with Canada on oil spill prevention and readiness programs within Puget Sound. A
Marine Manager Workshop on Major Oil Spills in 2012 is a good way to facilitate Canadian
cooperation on the topic. To support the NTA on shoreline development, consider the GreenShores
program which Environment Canada's EcoAction program funded in partnership with other
provincial and local organizations. Greenshores provides tools for sustainable planning and
development of coastal systems.

Greenshores Program: http://www.greenshores.ca



How can Kokanee be documented in marine waters? Are they not landlocked by definition?

In multiple places throughout the document the “San Juan Initiative recommendations” are
mentioned. It would be useful to provide a reference for those materials or identify them in the
Action Agenda so that readers unfamiliar with this initiative and its recommendations can review
them.
D.3.2, NTA 2:
BIAW supports the idea of a conducting cost/benefit analysis as a key action in the Action Agenda. It
is critical to make sure the actions undertaken – past, present, and future– are held accountable and
prioritized. BIAW also supports adding a cost/benefit analysis into all actions undertaken, as it would
make it easier in the future to determine what is effective.

BIAW also supports the issues addressed by others in the business community, such as the
Association of Washington Business, in funding, prioritization, action, and process. BIAW encourages
the PSP to address the gaps between the targets and near-term actions versus ongoing actions.

Other areas the Partnership should address are regulatory reform and economic impact. The
business community has long advocated for streamlining laws and regulations, especially those that
deal with the environment and land use. The processes of review are cumbersome, costly, and
counter-productive to the Partnership’s goals. None of the NTAs address real comprehensive
regulatory reform. BIAW urges the Partnership to truly address economic impacts. It is important to
develop a target to measure the health of our economy and evaluate whether actions taken on to
restore the Sound also impact the region’s economic health.

BIAW supports adding language to the Action Agenda that states the document should not be taken,
intentionally or unintentionally, as mandates on local governments. History shows that agencies with
Task 7.5 Near Term Action 1, ''municipal NPDES partners develop business plan for STORM." Staff
supports developing a work plan to efficiently and effectively educate the public about pollution and
clean-up effort. Building supporting documents to place STORM in a good position for grant funding
is needed and supported. However, the business plan should not be limited to municipal participants
and funding elements should not be linked to NPDES permits.

p. 278 Local Integrating Organizations (LIO) status: Please consider a near term action to set a date
for completing forming the remaining 3 LIOs? Absent a full suite of LIOs, the transition from Action
Areas to the LIOs remains incomplete, state agencies are without a central local entity to
communicate with about local priorities for a broad area of Puget Sound, local actions in these areas
may remain uncoordinated, coordinated local reviews of locally proposed grant applications remains
uncertain, and the voices of local citizens within these areas are disadvantaged relative to other
areas with functioning LIOs.
D.4
Comment: Linkages between the Action Agenda and Biennial Science Workplan are unclear both in the
organization of the Action Agenda, but also in the content. Yet-to-be determined priorities and strategic focus of
the Action Agenda should drive science/knowledge gap priorities.
Recommended Edit: Clarify relationship between these two documents

D.4
Comment: Science and monitoring strategy is buried under an inappropriate heading “Strategic Leadership and
Collaboration”.
Recommended Edit: Suggest this strategy has its own section.

D.4
Comment: Treatment of this strategy is inadequate. Science and Monitoring is described here as a component of
the “Backbone for Recovery and Protection of Puget Sound” but it has virtually no NTAs. Recommendations in
the Action Agenda are limited to continue ongoing programs. In many cases ongoing programs are inadequate
to provide the Science and Monitoring needed for recovery and protection. Moreover there is no consistent or
systematic message in the Action Agenda that the effectiveness of recovery actions be evaluated or monitored
in any way.
Recommended Edit: Recommend NTAs to (1) recover lost capacity for and fill gaps in Science and Monitoring
needed to support recovery targets, (2) identify effectiveness monitoring requirements and strategies for each
recovery target. See also comment above regarding the relationships between the Action Agenda and the
Biennial Science Workplan.

D.5 - On-going Programs
Comment: There is mention of PSP and Lead Organizations and local partners. WDFW oversees Regional
Fisheries Enhancement Groups.
Recommended Edit: Regional Fisheries Enhancement Groups should be recognized for their role in enhancing
Puget Sound either in Ongoing Programs or in near-Term Actions. (For example in near-Term Actions – Eco-Net
and STORM networks are recognized – the Regional Fisheries Enhancement Groups could also be recognized.

D.7
Comment: New sub-strategy needed.
Recommended Edit: D7.7 Engage volunteers to undertake field studies and stewardship that contributes to the
natural resource agencies mission to protect the health of Puget Sound.
Page 277, Partnerships

Please note that there are hundreds of local and regional volunteer groups and that they also work on habitat restoration
projects, issue advocacy, citizen engagement, environmental education, beach monitoring and cleanup, “keeper” boat patrols,
and dozens of other kinds of projects. This army of concerned and engaged citizens could be mobilized for real change.

Pages 279 – 281, Performance Management (Accountability)

Since the first Puget Sound primarily comprehensive management plan was adopted in 1987, its implementation has stalled
for two reasons, insufficient funding and lack of accountability. In recognition of the problem that no system of accountability
has been in place to ensure that regulatory programs and other aspects of the Puget Sound recovery effort achieve their
intended results, the legislature created accountability requirements for PSP and made these a key goal of RCW.90.71. Three
entire sections of the legislation include the word “accountability” in the section title, including section 350, entitled
“Accountability for Implementation.” Many sections refer to measureable outcomes, quantifiable performance measures,
measureable goals, how achievements of outcomes will be quantified, assessing performance, adopting and applying
accountability measures, accounting for funds expended. In section 350, the Leadership Council is to “….work closely with
existing organizations and all levels of government to ensure that the action agenda and its implementation are scientifically
sound, efficient, and achieve necessary results to accomplish recovery of Puget Sound to health by 2020.” The Council is to
identify local or state administrative or legislative actions needed to address barriers it has identified to successfully
implementing the Action Agenda (also section 350). This section also recognizes that an analysis of enforcement shortfalls is
essential to fulfilling PSP’s accountability responsibilities: “Among these measures, the council may hold management
conferences with implementing entities to review and assess performance in undertaking implementation strategies with a
particular emphasis on compliance with and enforcement of existing laws.” [emphasis added.]

Performance management, as described in this section of the draft Action Agenda, is a subset of the accountability
requirements in RCW 90.71. This section of the Action Agenda is where the full suite of accountability measures and
requirements of RCW.90.71 could be laid out. Please explain PSP’s plan to meet the statutory accountability requirements.

The Performance Management section of the draft mentions tracking achievement of milestones several times, but the draft
p.277, D2, new
Section is focused on the Puget Sound Partnership. Add a section about the Lead Organizations and
NEP/EPA funded programs.
In 2010, the Environmental Protection Agency issued a Request for Proposals to carry out priority
work consistent with the 2020 Action Agenda for the protection and restoration of Puget Sound. EPA
selected Lead Organizations (LOs) to coordinate six-year efforts to develop and implement strategies
in the four areas of emphasis:
Marine and nearshore protection and restoration (Departments of Fish & Wildlife and Natural
Resources). Watershed protection and restoration (Departments of Ecology and Commerce). Toxics
and nutrients prevention, reduction and control (Department of Ecology). Pathogen prevention,
reduction, and control (Departments of Health and Ecology).
For 2011 (Round 1), EPA allocated $3.1 million and provided another $5.5 million to fund projects in
2012 (Round 2), matched dollar-for-dollar by the states. LOs are working together to coordinate the
grant programs and each LO is working with local communities to support projects to achieve the
goals and targets in the Puget Sound Action Agenda.
My Special Concerns
* Citizen input is invited, yet not well received, is ignored and has no impact on PSP’s Action Agenda
* Citizen volunteer action to restore degraded reaches of streams, wetlands, ponds, lakes and Puget
Sound is both discouraged and thwarted by current environmental regulations, ordinances and
agency personnel attitudes
The Problem as I see it
* Water bodies throughout the entire Puget Sound Basin are degraded and require restoration, not
preservation and protection in their current degraded state
* Citizen and agency acts of restoration are made more difficult, costly and time consuming as a
result of blanket and indiscriminate application of current environmental regulations, local
ordinances, multiple agency approvals, and agency personnel attitudes
One of the avowed purposes of the PSP is to: “D.4.1 Align federal, state and local agency programs
in Puget Sound to improve coordination, efficiency, and effectiveness of implementation. This
means identifying overlapping authority and conflicts, and amending, realigning, or eliminating
programs, laws, and regulations that are not resulting in desired outcomes.” [PSP Action Agenda
page 65]
* In spite of a charter to correct this situation PSP has done very little, if anything, to address this
problem.
What Needs to Happen
* PSP needs to encourage, listen to and incorporate citizen input into its Action Agenda
* PSP needs to act to encourage and empower citizen volunteer participation in the restoration of
degraded stream reaches, wetlands, ponds, lakes and Puget Sound
* PSP needs to act at the legislative level to change environmental regulations, local ordinances and
Promoting Regional Stewardship
EJWC strongly supports public education, outreach, and technical assistance. Local groups such as
multi-stakeholder groups established under RCW 90.82 can help deliver and expand the reach of
education and technical assistance programs.
Strategic Leadership and Collaboration
D2. Strategic, Collaborative Partnerships
D2.1 Local Integrating Organizations: enhancing coordination and local recovery actions.

“In any given area, there are many local groups working on recovery-related activities, and these
groups are often not adequately connected to each other. PSP is working with local interests to
better coordinate implementing partners, and create a more efficient and effective approach to
clarify local priorities, accomplish identified work, address problems, and provide technical support.”

Recommendations:
Make NTAs such as:
- Devote consistent staff time to MSP initiatives
 -List partnerships and coordination mechanisms which can be used to support MSP efforts. The
creation of stakeholder engagement mechanisms and coordination of local efforts created by the
Local Integrating Organizations supports MSP and can become a part of the extensive stakeholder
outreach required in a future MSP planning process.
-For the LIOs, what is the relationship to existing authorities?
-Nest these efforts into larger state and regional efforts
-Link to existing information mechanisms and decision making processes. For example, acknowledge
state actions and need for regional scope, particularly in aquaculture.
Strategy D, Subtask 3.1, NTA#1 (Page 35) A GIS based reporting system to support Vital Signs would
be a great step in the right direction. In the development of transboundary indicators, cross border
comparisons would be greatly facilitated by increasing access to the data through the Vital Signs site.
To date, we have had to access data through specific Vital Signs authors which creates extra work for
the authors. Frequently, the response time is long and sometimes there is no response at all.
Increased data access through a GIS system would improve the ability to update the indicators
efficiently.

D2 (page 277 on strategic collaborative partnerships) -- Transboundary collaborative partnerships
with Canadian, provincial and local initiatives north of the border could prove mutually
advantageous. Both the Science Plan and Executive Summary identify many opportunities for cross
border collaboration on science initiatives and actions alike. Formal and adhoc collaborations on
transboundary issues (e.g. migratory birds, marine survival of salmon, downscaling climate
predictions and climate adaptations, transboundary watersheds) should be advocated.

D1 (page 275 on leadership) -- As a result of the many opportunities for transboundary collaboration,
consider Canadian representation on the Science Panel, Ecosystem Coordination Board and Local
Implementation Organizations for areas adjacent to the border including the San Juan Islands, Skagit
County Watershed, Strait of Juan de Fuca and Whatcom County WRIA 1.

D3 (page 281 on performance measurement) -- A Canadian interdepartmental project is currently
underway to value ecosystem goods and services, with a goal to reflect our natural capital in national
accounts. Analysis of costs and benefits of key actions undertaken in the Action Agenda could
include accounting for ecosystem goods and services restored as well as the economic returns for
Page 95. Strategic Leadership and Collaboration. D3 is omitted from the current draft. We
recommend inserting the following as D3. Making specific recommendations to the Legislature, state
agencies, and local governments for legislation and regulations necessary to implement near term
actions.


Page 275. Backbone support – statute mandated (D1.1). It seems that other key functions that have
been assigned to the Partnership, in addition to the Salmon Recovery Board, should be mentioned
here such as the Oil Spill Crosspartnership Workgroup.
Page 284. Monitoring Program – near-term action (D4.2). The Partnership should also be responsible
to ensure that adequate monitoring is occurring and that it is funded. These are key gaps. For
example, the Partnership has set a target for EDCs in English sole. There should be a near-term action
that addresses the needed funding for monitoring, especially for the targets.
Page 289. Puget Sound Starts Here near-term action (D6.1). To date, the Puget Sound Starts Here
campaign has been limited to stormwater issues. This is not mentioned in the text and the campaign
is being given significant prominence in the draft Action Agenda. Will it now be expanded to include
additional Puget Sound issues?
D2 “Strategic Leadership and Collaboration - Partnerships” (pages 277-278) - No mention is made of
how, and on what priority issues, coordination with Canada will occur. A sub-strategy for
transboundary collaboration might include several elements, including seeking Canadian
representation on one or more of the Partnership forums (Science Panel, ECB, etc.). We recommend
adding an element on transboundary collaboration to this section.

D4.1.1 (pages 284-285) “Continue to build an accessible, peer-reviewed base of scientific knowledge
about ecosystem status…” - The Partnership should indicate how it will learn from the experience of
other ecosystem restoration programs around the country. The valuable knowledge of other
programs could help inform the Partnership’s efforts. that the Action Agenda should include a
commitment to engage with this practitioner community, for example, through professional
associations such as the Society for Ecological Restoration, and through the biennial National
Conference on Ecosystem Restoration.

D4.1.1 (pages 284-285) “Continue to build an accessible, peer-reviewed base of scientific knowledge
about ecosystem status…” - As part of this sub-strategy, the Partnership’s Science Panel should
oversee development of conceptual models for ecosystem indicators/targets (note: a conceptual
model is different from a results chain in that the results chain graphically displays the logic by which
the Action Agenda strategies, NTAs, and targets relate, but it does not attempt to display how an
entire system works; whereas a conceptual model represents explicitly and graphically our best,
most complete working scientific understanding of the system we are trying to affect). For examples
of conceptual models for ecosystem restoration, see Doren et al.,2009 . It would be appropriate for
the Science Panel to develop conceptual models for each of the Puget Sound ecosystem recovery
targets as these would transparently illustrate our best working knowledge of how the system works
NTAs we support:
We support the concept of conducting a cost/benefit analysis of key actions undertaken in the
Action Agenda. In fact, this step is critical given our limited resources for Puget Sound recovery and
the need to prioritize actions. As such, Strategy D.3.2, NTA 2 (developing an approach for
collaborative analysis of data on the cost/benefit of key actions undertaken in the Action Agenda)
appears to move us in the right direction.
Partnerships p. 277 - (Add) Northwest Straits Initiative as one of three 'important areas of broad
collaboration' (currently only one – LIOs – is listed). We have the experience and ability to provide
technical, strategic and other support at the local level.

Continue and Expand Stewardship p. 286 – 287 - Stewardship evolves from the local community as
well as from a regional approach. Northwest Straits Initiative is a catalyst for locally-driven protection
and restoration efforts involving hundreds of community volunteers who help change stewardship
behavior, and should be explicitly recognized in this section of the document. WSU Beach Watchers
is another organization that should be acknowledged in this section for its ability to expand
stewardship at the local level.

Leadership p. 275
Ongoing Programs: (Add) Northwest Straits Initiative; through its Commission and MRC members.
Near Term Action: Northwest Straits Initiative will continue to serve as lead convener and facilitator
of 1) derelict fishing gear removal and 2) forage fish protection.
Science and Monitoring p. 282 (Add) Northwest Straits Initiative will expand partnership with
Washington Sea Grant to collect nearshore data needed to inform restoration efforts in 7 counties.

p. 283 D4 1.1
Near Term Action: (Add) Fund the publication of existing relevant data.

D4 1.2
Ongoing Programs: (Add) Northwest Straits Initiative.

p. 290 D6
Ongoing Programs: (Add) “Northwest Straits Initiative”
Near Term Action: Full funding of the Northwest Straits Initiative
(Delete) the first Near Term Action, unnecessary given the status of restoration efforts in this region.

p. 293 D7.4– The intent of the local South Central action is misinterpreted under this sub-strategy.
Pg. 293 D7
As discussed in the Caucus Group, this is better placed under D1. It is also the most frequently
referenced need in the group, so is very important to “get this right”.
Thank you for the opportunity to provide comments on the 2012 Update to the Action Agenda and Draft 2011-
2013 Biennial Science Work Plan (BSWP). On behalf of the Puget Sound Ecosystem Monitoring Program
(PSEMP), we understand the importance of both these documents to the protection and recovery of Puget
Sound.

As you know, PSEMP was only recently formed by the Leadership Council, building from a long history of
monitoring in Puget Sound including the earlier Puget Sound Assessment and Monitoring Program (PSAMP) as
well as many individual monitoring efforts implemented by agencies, tribes, and private organizations across the
region. Our Steering Committee, comprising 23 different agencies, governments, and organizations across
Puget Sound, first convened in June 2011. Since then, we have successfully adopted by-laws, elected a chair and
vice-chair, scoped and commissioned seven technical work groups, provided the data and results for the
Dashboard of Environmental Indicators, and began drafting a work plan and guidance that will lead to a better
overall understanding of monitoring priorities across Puget Sound by year’s end.

It is important that the Action Agenda and BSWP recognize the importance of monitoring, and we are gratified
to see a number of such references throughout the two documents. Monitoring is the mechanism that provides
the actual data required to both target and track the effectiveness of the actions recommended by these plans.
Monitoring also allows the Partnership to improve adaptive management of Puget Sound at both local and
regional scales, and it provides an on-going and objective record of the condition, status, and changes over time
of key ecosystem components and attributes- including the environmental indicators and recovery targets
recently adopted by the Puget Sound Leadership Council.

We note, however, that as presently written monitoring is addressed unevenly throughout the Action Agenda in
particular. For example, there are a number of Near Term Actions calling for very specific monitoring programs
(e.g. pg 70 placeholder NTA for effectiveness monitoring of status and trends of floodplains; pg 76 mention of
restoration project monitoring; pg. 82 effectiveness monitoring for mitigation sites, pg 109 monitoring for
priority invasive species (and pg 159 separate mention of monitoring for invasive marine species); pg 117 project
monitoring to implement adaptive management; pg 141 compliance monitoring for nearshore and marine
protection; pg 263 freshwater beach monitoring; pg 264 monitoring effectiveness of water quality improvement
A number of actions relate to stewardship in section D: NTAs 5.1 through 5.6 and 6.1 through 7.6.
These actions do not recognize the public education and stewardship that are currently being carried
out. We recommend that a complete inventory and assessment of education and stewardship
activities first be conducted to see if existing programs can be improved or modified to achieve the
desired outcome before recommending new duplicative programs.


D.2: This strategy fails to account for ground-up aggregation of local stakeholders’ knowledge and
integration into Partnership planning. Since LIOs are each an individual stakeholder, limiting
Partnership interaction in certain areas to that obtained through the lens of a LIO means that the
many, many local stakeholders are limited to Partnership access by the LIO. Where LIOs are the
primary connection of Partnership to local action, the Partnership should establish a feedback loop
that allows local organizations that may have a differing opinion from the LIO to be heard. This is
partially captured under D3 NTA 2, but the need for feedback to partnership on the performance of
the LIO is missing.
D.4.2: The need to ensure adequate monitoring and research programs are maintained and that
funding is available should be a responsibility of the Partnership and should be addressed in this
document. (p. 284)
D.5: While perhaps it should be referenced elsewhere, section D5 should also include reference to
the FEMA BiOp that may challenge all current uses, in particular current or future building projects,
in Puget Sound floodplains. Section D5 NTA 3 performs a similar function w/reference to STORM, but
the FEMA decision could have vast and far-reaching consequences.
D1 Provide the leadership frameworks to guide the Puget Sound recovery effort and set action and
funding priorities.

When the Puget Sound Partnership was founded, it was our hope that this new agency, not
beholden to any other and reporting directly to the Governor, would be able to transcend agency
politics and become a true advocate for the Puget Sound ecosystem. We were hoping that the
Partnership would align the efforts of local and state jurisdictions, eliminating common barriers to
recovery and streamlining recovery efforts that were consistent with Action Agenda strategies.
Unfortunately, we have not so far found this to be the case.

As you go through the process of updating the Action Agenda, we encourage you to think larger than
the individual strategies you have identified. We encourage you to incorporate the goal of becoming
a true advocate for Puget Sound. Search out and eliminate barriers to recovery that are under state
or federal jurisdiction, provide additional funding that local NGO’s, tribes and local jurisdictions alike
can qualify for, and find landscape scale solutions that will solve multiple Action Agenda strategies
simultaneously.

page 277 - Local Strategies insert
Change Request: Delete this confusing and potentially misleading sentence: The Strait has identified
this as a non-priority, yet important strategic area as well”. Formation of an LIO within the Strait
Action Area is
not a priority because it's already been accomplished! Replace this sentence with this one:
"Continuation of the Strait's already formed and functioning LIO is an important part of its local
strategy to implement the Action Agenda."

page 289 - Local Strategies insert
Suggestion: Add the Strait to this list. The Strait has already identified Climate Change as one of their
19 additional Strategic Priorities, namely "Climate Change Mitigation, Adaption, and Implementation
of Programs and Plans". One of the specific Priority Actions listed for this Strategic Priority is support
for "Outreach, Education, and Planning Efforts" related to local climate change related programs,
projects, local ordinances, etc.
Strategy D, subtask 2.1
Advance the coordination of local recovery actions via local integrating organizations

NTA #1
None

WSCC Comment: Concerns. Experience with similar local coordinating groups suggests caution with
the use of LIOs. It’s important that all key entities are involved at the local level and this is not always
the case. There should be some level of oversight by a state entity to ensure broad local participation
and an avenue for local entities that may be excluded from the process to voice their concerns.

Strategy D, subtask 3.2
Work collaboratively to report on recovery progress

NTA #1
PSP leads the building of a community of performance practice that is inclusive of local jurisdictions,
tribal governments and private organizations involved in the work of restoring the Sound. The goal is
to assemble and share data and experiences on sound recovery strategies techniques and outcomes

WSCC Comment: Support
C.9
Comment: Several areas in this sections have placeholders for the "who" and I am not sure who will
be deciding the lead agency or entity for these task.
Recommended Edit: Determine lead for unassigned NTA's.

C.9.5
Comment: With the Governor's Shellfish Initiative now completed, I assume the section on page 247
"Priorities in the Washington State Initiative" are being added?
Recommended Edit: Update C.9.5.1.
Page 244
Please note in Ongoing Programs the role of DNR in shellfish management through the aquatic
leasing program and the wildstock geoduck fishery management program.
p.238 - At end of vessel discharge section is a bulleted list of ‘Science Needs’ that includes: ‘Support for DOH’s ongoing work on technologies for nutrient reduction from
OSS.’ What is this doing in this sectio
p.241—243 C9. Narrative
See attachment 1and 2 in DOH comments: narrative updated with more current information and significant edits. In opening paragraph, no mention of water quality and
its relationship to shellfish harvest.
*p.242, Paragraph above section titled, ‘Ongoing programs’ - This paragraph infers that coordinated effort can increase the trend of upgrading acreage for shellfish
harvest, but ignores the fact that we have netted most of the ‘low hanging fruit’. Continued progress may require more effort and resources (including additional OSWP
staff to classify and monitor areas) than in the past.
p.243 Generic comment for NTAs: Performance measures need to be SMART (Specific, Measurable, Achievable, Realistic and Time Bound).
*p.243/244 C9.1 NTA 1 and C9.1 NTA2 - Combine into one NTA worded as follows.
Convene a forum of stakeholders and regulatory agencies to evaluate shellfish growing area restoration projects to:
-Create a best practices library or menu highlighting successful strategies to assist in the development of shellfish protection districts, shellfish protection programs, and
shellfish growing area restoration activities.
-Assess how state and federal agencies can enhance local governments’ efforts to respond to threatened and downgraded shellfish areas.
-Develop an agreement between state agencies regarding roles and responsibilities in responding to shellfish downgrades.
-Identify methods and tools that help identify and correct nonpoint pollution problems.
-Work with Ecology and other state and federal agencies to provide incentives for local governments for the long-term protection of shellfish growing areas.
p.244, C9.1 NTA 2 - This is way too generic and duplicates existing duties of shellfish protection districts and LIOs. Look at ways to empower SPDs and LIOs to do this
work.
p.244, C9.2 - Add DOH to the list of agencies that WDFW will collaborate with to restore native shellfish populations.
p.244, C9.3- Interesting here for two groups that aren’t mentioned: The Pacific Coast Shellfish Growers Association and World Wildlife Fund. PCSGA members had input
into global sustainability standards: http://www.worldwildlife.org/what/globalmarkets/aquaculture/bivalvestandards.html. Perhaps PCSGA can be responsible for a NTA
to disseminate these standards.
*p.245, C9.3 NTA 1 newThis NTA does not appear to be consistent with the overarching objective of the section. It applies to nitrogen removal using shellfish, not
environmentally responsible shellfish aquaculture for food. We have revised this NTA and included it in a proposed new section which describe a variety of shellfish
research projects and needs. See attachment 2 for new section narrative and NTAs.
p.245. C9.3 NTA 1 The project they are mentioning can be found here: http://www.restorationfund.org/projects/mitigation.
p.245, C9.4 NTA 1 Why have a NTA if you don’t know who will do it or how it will be measured? It sounds like spatial planning is a component of the shoreline master
programs that local governments are already responsible for.
p.247, C9.5 Shellfish Initiative—Pollution Action Team
NTA (Ecology is Owner): Departments of Ecology, Health, and Agriculture will form a Pollution Control Action Team (PCAT) designed to identify and address pollution from
a variety of point and nonpoint sources, including on-site sewage systems, farm animals, pets, and stormwater runoff that are affecting shellfish beds. Due to persistent
and growing concerns over vulnerable shellfish resources in Portage Bay and Drayton Harbor, Whatcom County has been identified as the initial focus area for a PCAT.
Performance Measure: Develop and implement the Pollution Control Action Team.
p.247, new Add new section: Emerging Issues and Future Opportunities: Specific longer-term activities to ensure that Washington’s shellfish are healthy and safe for
harvest were identified during the Action Agenda update process and include the following:
-Continue to characterize the extent of diarrhetic shellfish poisoning (DSP) in Puget Sound. This will include characterizing the species of Dinophysis that produce toxins
and developing rapid screening for toxin detection in shellfish.
-Evaluate and manage “Other” lipophilic shellfish toxins in Puget Sound, including efforts to identify and characterize the distribution of phytoplankton species that
produce azaspiracids, gymnodinimines, and yessotoxins; determine concentrations of these toxins in shellfish; investigate links to anthropogenic nutrient sources; and
establish protocols for quantifying these biotoxins.
-Determine whether anthropogenic nutrients exacerbate harmful algal blooms in Puget Sound. Recent evidence, in particular from Sequim Bay, indicate that the first
domoic acid closure was preceded by a pulse of high levels of ammonium, likely from heavy boating traffic over Labor Day weekend.
-Develop an early warning system for paralytic shellfish toxins (PSP events) by evaluating environmental factors promoting toxic bloom events. This will include a
retrospective analysis of the most toxic events and, in conjunction with weather forecasters, a forecast for PSP-causing harmful algal blooms in Puget Sound.
-Develop a predictive model for Vibrio parahaemolyticus using the “window of opportunity” approach that incorporates DOH environmental data collected over the past
decade, including information from the DOH oyster-based environmental surveillance program.
p.248, 1st para, last sentence - “into the water and contaminates the oysters, clams and mussels so they are not safe to consume.”
C9: Protecting Shellfish
C9.3 NTA 1: Suggest editing as follows: “DNR will work with Department of Ecology and stakeholders
to create pilot projects testing the use of mussel culture or other suspended or beach culture to
mitigate help address nitrogen pollution in sensitive areas, such as the project in Quartermaster
Harbor. This aquaculture application may serve to encourage public-private opportunities to reduce
nitrogen impacts that are both efficient and cost effective and provide an alternative to advanced
wastewater treatment technology.”

Note: This NTA should specifically mention that DNR will work with Ecology given the implications for
pollutant trading. The suggested edit to change “mitigate” to “help address” is subtle but important
given the implications for the federal Clean Water Act. The federal act provides for pollutant trading,
but not for “mitigation” as currently exercised through wetland management (i.e., wetlands can be
filled and recreated – i.e., “mitigated” – elsewhere). The CWA does not permit the violation of water
quality standards anywhere, so “help address” accurately reflects application of the law. The last
part of the last sentence “…and provide an alternative to advanced wastewater treatment
technology” should be deleted. This is far beyond where we are at right now.”
C9. Abundant, healthy shellfish for ecosystem health and for commercial, subsistence, and
recreational harvest consistent with ecosystem protection.
C9. 4 Resolve competing priorities between aquaculture and near shore, habitat and upland uses.
C9.4NA1: Will support pre-planning and implementation of MSP and local shoreline master program
updates by: gathering, compiling and ground truthing baseline information on current aquaculture
and filling data gaps and completing research to identify areas that are suitable and unsuitable for
future shellfish aquaculture.

Recommendations:
This is a good action.
Will the data collected have a spatial component for “identify areas that are suitable and unsuitable
for future shellfish aquaculture?”
Determine process to identify criteria with agencies for allowing “future shellfish aquaculture areas”?
Research listed in the BSWP (p24) focus on HAB research. Are areas with potential for HAB the only
criteria for determining these future aquaculture areas? Who is doing research to answer these
questions? (Perhaps provide this in action agenda)
C.9 Shellfish Health and Harvest (pages 241-247) - The shellfish sub-strategies and target relate to
mitigating and preventing sources of pollution that cause problems with shellfish area harvest
classification. The Biennial Science Workplan priorities for shellfish strategies also focus on pollution
issues that affect shellfish area and human health concerns (page 6, Answering the Call to Action
section). Some near-term actions and sub-strategies presented under strategy C9, as well as the
tone of the narrative, seem more related to expanding the potential for commercial aquaculture in
Puget Sound. It would therefore be useful for the Science Panel to review the assumptions,
proposed sub-strategies, and NTAs in this section to ensure that they reflect the highest-priority
actions needed to achieve the shellfish ecosystem target. Commercial aquaculture is economically
important from many perspectives and there is strong interest in promoting and supporting it, but it
is also important to ensure that where the interests of commercial shellfish aquaculture are not
aligned with ecosystem recovery needs, the pressing driver of commercial shellfish aquaculture does
not overcome the focus on achieving the ecosystem targets.

There are only three strategies listed to achieve the target of shellfish bed recovery (page 248), with
very few NTAs identified: C9.1 (two NTAs but one is a forum, see comment below), C5.3 (only one
NTA), and C11.4 (ongoing program only). There should be more NTAs identified to push this
important work toward the target.

C9.1, NTA 1 (page 243) “Replicate model programs, such as those in Henderson Inlet and Oakland
Bay, which create coordinated, locally-driven efforts to protect and improve shellfish harvest areas.
p. 244
Four MRCs are restoring Olympia oysters in partnership with Puget Sound Restoration Fund; in
Clallam, Jefferson, Skagit and Whatcom counties. Restoration is in coordination with, but not led by,
WDFW.

p. 247 C9.5
(Add) under implementing the Shellfish Initiative: The Northwest Straits Initiative was awarded
$200K to restore Olympia oysters, in partnership with Puget Sound Restoration Fund.
The Northwest Straits Initiative is well positioned to implement the Shellfish Initiative, by carrying
out projects to improve local water quality near shellfish growing areas, restore native shellfish
through out-planting, and increase awareness of recreational harvest opportunities.
Sub-task C9.1: This section provides valuable information about shellfish harvesting acreage. However, as
presented it is somewhat confusing and would benefit from some organization. It would be helpful if all Puget
Sound numbers were presented together. Also while the net change of classified areas (i.e. downgrades and
upgrades) is useful information, it is currently presented in a manner that is confusing to the reader. PSP needs
to simplify the information and provide it in a clear and logical way.
C9.I Ongoing Programs
• In an effort to better link the Near Term Actions to the discussion PSP should consider
including information about programs that would be appropriate to replicate.
• First paragraph, third sentence should read: Unless pollution problems are addressed,"Threatened" areas still
meet the standard for their current classification but, unless pollution problems are addressed, could soon be
downgraded ... "
• Page 243, forth sentence should read: "They are widely believed to be one of the single best approaches to for
protecting and reopening shellfish beds, and have been successfully been implemented in Henderson ..."
C9.1 Near Term Actions
• Near-Term Action 1 - Consider adding Samish Bay to the programs for which to replicate.
• Near-Term Action 2 - This action was included in an early draft of the WSI. While PCSGA feels it would be a
valuable exercise, it was ultimately not included in the WSI due to concerns for resources to accomplish it and
lack of a willing leader. In our opinion this would be an appropriate action for the Partnership. Such a review
would provide an assessment of the efficacy of existing programs, identify gaps and where potential
improvements could be made and replicated. Near-Term Action 2 would be stronger if it was made clear that a
primary focus of the forum is to improve coordination and to ensure appropriate action is taken to address
threatened areas before they are downgraded.
• PSP should add the following action from the WSI as a Near-Term Action: Form an EPA and state (i.e.,
Departments of Ecology, Health, and Agriculture) ''pollution action team" to respond quickly when water quality
problems are identified that threaten shellfish areas.
Sub-Task C9.2
Page 242, under Ongoing Programs, in first sentence after “Tribes,” please insert “Washington Sea
Grant”. Teri King, South Sound Water Quality Specialist is fully integrated into this effort.
Page 245, under Key Ongoing Program Activity, should read, “Washington Sea Grant and university
researchers will complete….”
Page 245, under C9.4, remove “on the scope of research” from the last sentence in that paragraph.
Page 247, under Implement Washington State’s Shellfish Initiative, please include Washington Sea
Grant with other cooperating organizations and agencies when more description is added to this
section.
Strategy C, subtask 9.1
Improve water quality to prevent downgrade and achieve upgrades of important current tribal,
commercial and recreational shellfish harvesting areas.

NTA #1
Replicate model programs, such as those in Henderson Inlet and Oakland Bay, that create
coordinated, locally-driven efforts to protect and improve shellfish harvest areas. Create a best
practices library or menu highlighting successful strategies so that jurisdictions do not have to
reinvent the wheel.

WSCC Comment: Support. Recommend designating the Conservation Commission and the
PSPartnership to work together on this NTA.

Strategy C, subtask 9.1
Improve water quality to prevent downgrade and achieve upgrades of important current tribal,
commercial and recreational shellfish harvesting areas.

NTA #2
[Who?] will convene a forum of stakeholders and regulatory agencies involved in the restoration of
water quality in shellfish growing areas to: § Assess how state and federal agencies can enhance local
governments’ efforts to respond to threatened and downgraded shellfish areas. § Develop an
agreement between state agencies regarding roles and responsibilities. § Identify methods and tools
that help identify and correct nonpoint pollution problems. § Provide incentives for local
Local Action Agenda in Skagit County/Watershed (page 346) The Skagit Environmental Endowment
Commission includes representation from British Columbia and Seattle City Council to administer an
Endowment Fund whose purpose is "to conserve and protect wilderness and wildlife habitat" and "to
enhance recreation opportunities" in the Upper Skagit Watershed. The Commission has established
an ecosystem management plan which may yield commonalities with the provisional NTAs presented
in the absence of a Local Integrating Organization.

Skagit Environmental Endowment Commission: http://skagiteec.org



No group has formed for this area and no new prioritization has taken place since 2008. Although
salmon recovery strategy depends on Skagit delta restoration, no particular emphasis or
acknowledgement of that is in this local chapter of the Action Agenda. While climate change is listed
as a major threat, no actions to adapt to climate change are identified, specifically sea level rise
which has the potential to wipe out many of the existing salt
marshes outboard of agricultural dikes as well as threaten the Skagit agricultural system and
associated communities itself.
The Action Agenda for Skagit County/Watershed
The opportunities, priorities, and near term actions section of the Skagit Profile has a relatively
complete view on necessary management actions for the county, with the notable exception of
addressing the existence of dikes, their management, and their susceptibility to impacts from wave
action due to sea level rise. As the primary engineering structures impacting water flow and mixing in
the Skagit Delta, these dikes and their existence should at least be noted directly instead of obliquely
through “Skagit Delta Drainage and Fish Initiative - Maintenance Plans” and “Skagit Delta Tidegates
and Fish Initiative Agreement.”
To begin, we note that the list of priorities and near term actions is developed from the 2008 Action
Plan, the Whidbey Basin Profile, and initial updates for 2011. We would request that this set of
strategies continue to be developed.
The Skagit Action Agenda identifies climate change as a major threat to the Skagit region. However,
there are no actions identified that address changes related to climate change, such as sea level rise.
We request further development of strategies that address the threat of climate change and sea
level rise to the agricultural system, shellfish industries, and the communities within Skagit County.
The sub-strategy relating to the protection and restoration of marine and nearshore ecosystems is
incomplete, as it fails to explicitly address management for shoreline armoring and overwater
structures; these are addressed with great detail in the Puget Sound Action Agenda. In addition, we
Comments on Action Agenda for the Skagit Watershed
• The title “The Action Agenda in Skagit County / Watershed” is misleading and incorrect. The Skagit
Watershed bounds three counties (Skagit, Snohomish, and Whatcom) and two countries (United
States and Canada). The upper 300 square miles of the Skagit Watershed is located in British
Columbia, which is definitely not part of Skagit County.

• The Action Agenda states that the content of the Skagit Action Agenda “section was obtained from
two primary sources: (1) background material presented in the 2008 Action Agenda; (2) information
developed in the process of collecting feedback on a template from those entities that had time to
engage in the process.” The latter process resulted in few responses because the response period
was short (a couple of weeks), and because the template was so large and complex the most
potential respondents did not have the time or the patience to fill it out.

• Several sources of information that were not used (but could have been) for the Action Agenda
include the 2010 update of the Skagit Watershed Council’s three-year recovery program, the was
2010 Strategic Plan Update, the 2005 Skagit Chinook Recovery Plan, the 2011 Middle Skagit Project
Development completion report submitted to PSP and the SRF Board, and the Habitat Work
Schedule web database that was developed and funded by the State of Washington. These
documents are available from the Skagit Watershed Council’s web site, which was not listed in Action
Agenda’s “references and additional resources” section for the Skagit. The Skagit Watershed
Council’s web address is: http://www.skagitwatershed.org/

• We would recommend downloading the 2010 Strategic Plan Update first, since this provides an
Please accept the following text for consideration in your Skagit profile. We believe this text could
follow your section on Key Threats/Pressures and precede the section Opportunities, Priorities, and
Near Term Actions. Given what the Skagit Climate Science Consortium
(www.skagitclimatescience.org) has found regarding specific impacts of climate on the Skagit basin, it
seems worth including more specifics on both the impacts we have seen, are projecting into the
future and key scientific research areas targeted to produce better information for decision-makers.
You will note the science is explained in some detail so that people see the connection between the
research and what is important. The priority research could, in addition, be simplified and added as
preliminary ideas on near-term actions in your table. Many of these priorities are also regional
priorities worthy of consideration for the Science Plan.

As you know, the Skagit Climate Science Consortium is a 13-member collaboration of research
scientists working on climate related issues in the Skagit from USGS, UW, TNC, Seattle City Light,
Swinomish Tribe, Skagit River System Cooperative, NOAA, etc. The following comments reflect our
collective views and priorities.

The significance of the changes in climate faced by those working to protect and restore Puget Sound
for people and ecosystem health cannot be overstated. The following information provides some
toeholds into both the substance of what we know about these changes and provides the rudiments
of a pathway forward. This opportunity to include this information in the Action Agenda is even
more important, because our organization exists for the sole purpose of 1) conducting timely and
relevant climate research and 2) working with local decision-makers to understand, refine and apply
these findings. We believe this is a unique opportunity where not only are people presented a set of
important questions to face and answer, but also the resources and support to do the work.

We hope you will consider these additions to the profile. We would be happy to work with you to
refine or improve our comments. I can best be reached via email during the workweek.

Sincerely,

AlanSkagit Chapter Profile 27 pg 346-361 lacks a creditable or tangible path forward. It is well
The Hamlet 
understood that this deficiency is the result of a lack of a coordinated discussion and agreement on
the Local implementation membership, structure, and function. Once some of the issues previously
stated in the letter are addressed, the Tribe would like to further discuss moving forward on the
Skagit chapter. The Tribe supports the reference to 2 projects ready for implementation from the
Middle Skagit Restoration planning work. Although no detail is provided the Tribe supports the
implementation of habitat protection and restoration projects that are ready to implement. In
addition The Tribe has partnered with Skagit County on developing the conceptual design of the
Freestad Lake Project, and encourages financial support to implement this restoration project.
Programmatic implementation is necessary across air, terrestrial, riverine, near shore and marine
resources at federal, state and local levels. Continued data collection through assessment and
monitoring, maintenance and stewardship are requisite actions. Essential efforts in response to
Treaty resource risks require the Tribe to maintain response flexibility in harvest and hatchery
management, all H integration, and monitoring and adaptive management needs while supporting
• Perhaps a through programmatic implementation. function of the Partnership staff would be
restoration reference to the soundwide accountability
appropriate, although the sheer number of actions would be difficult for Partnership staff to track
unless the South Central LIO performed detailed self-reporting.
• The Maury Island Aquatic Reserve and the recent acquisition by King County of the gravel mine site
are important conservation accomplishments for this action area and should be called out as part of
the context, if not a notable accomplishment since 2009.
PSRC's Continued Participation. PSRC supports the mission and goals of the Puget Sound Partnership
and recognizes the scale of the challenge it faces in restoring Puget Sound. PSRC will continue to
participate in the process through the South Central Action Area Caucus Group. The caucus group
must be supported as an entity of the Partnership, rather than a stand-alone group, with Partnership
staff continuing to play a lead role.
Stormwater-related issue in the South Central Action Area Caucus
• p. 365. Item D doesn’t make sense as written. Suggested rewrite “Fund stormwater retrofits and
operations/maintenance of existing stormwater infrastructure.” This should also be broadened to
match table for fund SWMPs – it’s not all about the structural.

• p. 365. Item G should be written to avoid the term “waste stream” as it seems to imply
wastewater when it also applies to stormwater.


• P. 365 Overall A-G list seems habitat heavy – there should be a reasonable balance. Adding first
item above would help

• p.366 Note Policy Alignment – first column is same as last.

• p. 368 “True Source Control” – yeah! Seems to link will with lots of AA items in C.1.


• p. 371. Under Stormwater for Local Issues, add the non-structural. This is a mixed column of
solutions (e.g., retrofits) and problems (e.g. disruption of natural hydrologic regime). Not sure what
is intended. If problems should include categories of polutangs (conventional, toxics, organics,
nutrients, etc..) and sources (industrial, transportation, commercial, residential, deposition, etc…). If
solutions, should include “true source control”, business inspections, E&O and other
P. 364, last bullet. Not clear what “Toxics and excess nutrients in the marketplace” mean. Clarify or delete “in the marketplace.”

• We recommend adding Yelm and unincorporated Thurston County to the rapid growth centers in
South Puget Sound and attribute a great amount of that growth to Joint Base Lewis McChord staffing
up for the wars in Iraq and Afghanistan.
• In the notable accomplishments box, Devil’s head is part of the Key Peninsula, not Anderson Island.
• While not necessary to list in the notable accomplishments, even though it is one, is the
designation of the Nisqually Reach Aquatic Reserve, the only such habitat protection strategy in
South Sound and as significant to context the conservation portfolio of South Sound as are upland
and watershed conservation areas like the Nisqually National Wildlife Refuge and Mount Rainier
National Park.
• It should be noted that the history of the shellfish industry has shifted the ecological makeup of
South Sound from one that was dominated by the native Olympia oyster to one of a mixed wild and
non-native shellfish fauna that includes tended and escaped non-native species and unintended
“piggyback” species such as Japanese oyster drills, Atlantic slipper limpets and Japanese eelgrass.
• Since spatially explicit actions were identified in this Action Area, that matrix should be available in
this chapter as a link. Similar to South Central, the prioritized actions should be assigned and tracked
for self-reporting by the LIO to the Partnership to allow an efficient oversight and accountability role.
• The loss of the Deschutes Estuary is one of the most significant alterations to historic conditions
Please include a stronger effort to restore habitat in South Puget Sound/Budd Inlet by openly
supporting Deschutes Estuary restoration.
South Puget Sound Action Area
In the South Puget Sound Action Area, we have formed the Alliance for a Healthy South Sound. The
Alliance was established by formal local legislative resolutions of the Pierce County Council, Nisqually
and Squaxin Tribal Councils, and the Boards of Commission of Mason, Kitsap and Thurston counties.
The Alliance has formed an Executive Committee of elected officials from those jurisdictions and a
broader South Puget Sound Council foradvisory purposes. The Alliance was recognized in 2011 by
the Partnership’s Leadership Council and awarded operating funds. Workgroups of the Alliance are
working with Partnership staff to prepare and submit Action Area priorities for inclusion in the final
Action Agenda for South Puget Sound. Partnership staff have committed to include those priorities
as submitted and approved by the Alliance. Pierce County supports locally-derived priorities for
South Puget Sound and recommends the Agenda be revised to specifically incorporate them as
submitted.

• This chapter includes a long list of activities which are still unprioratized.
• This area is similar enough to Whidbey Island/Watershed and Skagit outcomes that we don’t
understand why the Whidbey Basin Action Area needed to be separated into three groups.

On Page 384, the third complete sentence near the top of the page should be revised to read,
“…more local science needs exist, and the development of the full suite of local science needs is yet
to be done.”
Page 384 – typo under Key Threats/ Pressures, 3rd line down - “treats” should be “threats”.


Page 385, Pollution threats – Nutrient loading.

This section says that nutrient loading contributes to eutrophication and naturally occurring low
dissolved oxygen concentrations in Penn Cove, Saratoga passage, Possession Sound.

Natural density stratification occurs in these water bodies, and with that there can be naturally
occurring low dissolved oxygen. However, nutrient loading is not a contributing factor to
eutrophication and the low dissolved oxygen. The wording should be changed to reflect that there is
naturally occurring low dissolved oxygen in these waters, and nutrient loading might or might not be
a concern.

Page 393, Implement coordinated integrated ecosystem monitoring program

The first bullet needs to be changed as follows:

Evaluate low dissolved oxygen levels in Possession Sound and develop and implement strategy to
address low dissolved oxygen levels as if necessary.

p. 385, and 387 (Delete) 'Bay' following Port Susan
p. 387, 389 (Change) Port Susan Bay Planning Area to Port Susan Marine Stewardship Area
p. 389, 390, 391, 392, and 394 (Delete) 'Bay' from Port Susan Bay MSA (to read Port Susan MSA)
Polluted stormwater runoff is one of the leading causes of pollution to our streams, rivers, the
coastal marine environment and other large waterways around the country, including Puget Sound.
However,
existing pollution controls and management approaches for these discharges are inadequate.
Therefore we strongly support the draft Action Agenda finding that reducing and controlling the
sources of
pollution, including stormwater runoff, to Puget Sound is of paramount importance to the long-term
health of the Puget Sound ecosystem.

Section C2.2 focuses solely on problems associated with new development. However, at the site and
subdivision scale, problems from both new development and redevelopment should be addressed
and discussed in the Action Agenda, with the same requirements applying to both. This approach is
consistent with Ecology’s recently released draft Phase I permit for W. Washington and draft Phase II
permits for W. and E. Washington all of which incorporate requirements applicable to both types of
development.

In general, the ongoing impacts of stormwater runoff to Puget Sound require a paradigm shift in how
we regulate and control stormwater. The draft Action Agenda identifies several key elements of this
shift, in particular the need to focus on Low Impact Development (LID), which we strongly support. In
the context of stormwater management, prioritizing LID stormwater management practices that
mimic natural hydrology and provide cost effective solutions that measurably reduce flooding and
improve water quality is required. Requiring LID solutions such as pervious pavement, green roofs
and rain barrels in stormwater permits will improve the health of Puget Sound. The Action Agenda
should support strong LID requirements in all stormwater NPDES permits, including maximizing
native vegetation and decreasing impervious areas.
C2.2, All NTAs:
BIAW takes issue with blaming new development for significant stormwater-related problems.
Thanks to current stormwater control practices, new development has relatively little run-off
pollution compared to historical development and, even if new construction added zero impact to
stormwater pollution, the Puget Sound would still have a stormwater problem due to “sins of the
past.” BIAW specifically opposes NTA 4, spending any resources on Washington’s current state
vesting laws is inappropriate and does not serve the restoration of Puget Sound. Vesting rights have
been well established and upheld repeatedly in Washington courts. Washington builders rely on the
certainty and stability that vesting laws provide. Please do not add to the building industry’s
instability.


• Task 2.1 - Near Term Action 2, "mapping." It was unclear whether this action was to describe
elements that should be displayed or specific software or protocols for mapping? There should not
be any specified platforms or protocols at this time, as moving from one system to another would
require substantial lead time and additional funding.
• Task 2.3 - This sub-strategy needs to be carefully defined so it does not assume NPDES regulatory
status. Staff suggest that any actions within the basin or watershed context be voluntary and require
all affected jurisdictions to agree on the strategies.
- Near Term Action 2, treatment standards for more than sediment. What types of treatment are
being considered? There are limited BMPs that address dissolved chemicals and they are typically
fairly expensive to retrofit and maintain.
- Near Term Action 3, legacy pollutants. What type of guidance is being considered for pollutants
that are already outlawed and local governments may have limited ability to influence further?
Page 178, Runoff from the Built Environment
Please add a bullet under "The Challenge" that stormwater is a significant contributor of toxics to
marine sediment contaminated sites.

Please add in the 3rd bullet on high flows that harm includes scoring of stream beds.

Page 179, Runoff from the Built Environment
Please note that the municipal NPDES stormwater permit itself needs to be strengthened, as does
the program itself. (See DNR comment letter on these permits.)

Page 182, Runoff from the Built Environment
Please note in the paragraph on "Land Use and Stormwater" that land use actions should be
required to meet state water quality standards. This is the only way to truly integrate land use in a
way that reduces stormwater pollution.

Page 184, Runoff from the Built Environment
Under "Consistent Management of New Development Basin-wide”, it should be noted that the
Stormwater Manual for Western Washington itself states that compliance with the Manual will not
achieve water quality standards. Please explain how this will achieve recovery by 2020.

Page 185, Runoff from the Built Environment
NTAs should be developed under C.2.2 to increase permit fees for the NPDES program at Ecology so
that it is fully funded, to bring unpermitted dischargers into the permit program, to update AKART,
p.185 - C2.2 NTA 1 - What is target for financial assistance?

p.185 - C2.2 NTA 2 - In performance measure, ‘evaluation’ should be replaced with ‘draft treatment
criteria’

*p.185 - C2.2 NTA 3 - There are few marine areas having both urban stormwater problems outside
permitted areas and priority shellfish growing areas. The performance measure is unclear, but it’s
not possible to document reduced impacts by September 2012. Move deadline for initiation of work
to 2013. Suggested language for performance measure: Identify sites and initiate assistance to local
governments in non-permitted areas by September 2013. Assess reduced impacts at conclusion of
project.

p.185 C2.2 LNTA 5 - General comment – noted a disproportionate number of NTAs geared towards
San Juan County – is this a ‘squeaky wheel’ artifact or statement of actual need? (see also C2.4 NTA
3, C2.6 NTA 1, C5.1 NTA 4, C10.1 NTA 3). Shouldn’t there be more balance in PS localities
represented in NTAs?

C2.1
P.181 EJWC supports managing urban runoff at the basin and watershed scales. In particular, we
support promotion of low impact development and incentive programs.
P. 182 Land Use and Stormwater – EJWC agrees that water resource planning and land use planning
should be better connected and aligned. EJWC recommends option 2, supporting and funding the
development of WRIA plans that address the full spectrum of water resource elements and land use
on a regional basis.
C2: Stormwater
C2.1 NTA 3: It might be possible given sufficient staff and funding to have this in place in time for the
2018 permits, but integrated mapping is not currently envisioned for re-issuance of the muni
permits. Locals are mapping their systems but there isn’t an “overall geo-referenced database” for
the locals to populate and one will not be ready before the permits are issued in July 2012. Ecology
currently has guidelines for creating and accessing GIS Data under Ecology Grant programs available
on-line: http://www.ecy.wa.gov/services/gis/data/standards/standards.htm In an effort to better
assure compatibility and encourage sharing of geospatial data among a variety of users, both public
and private, Ecology encourages grant recipients to embrace these standards.

C2.2 NTA 1: Add issuance of the municipal stormwater permits (6/2012) to strengthen and refine
stormwater management efforts currently underway under the NPDES permits. This may allow you
to combine the first NTAs in this section.

C2.2 NTA 2: This is being done. Ecology’s Water Quality Assessment Program assesses whether
treatment standards beyond basic are required and lists the water quality status for a particular
location in one of 5 categories recommended by EPA. The assessment represents the Integrated
Report for Sections 303(d) and 305(b) of the Clean Water Act. Water Quality Improvement Projects,
or TMDLs (Total Maximum Daily Loads) determine the amounts of pollutant loading that a given
water body (river, marine water, wetland, stream, or lake) can receive and still meet water quality
standards. Where water bodies do not meet water quality standards for a particular pollutant,
TMDLs are implemented through Waste Load Allocations, inserted as pollutant limits in permits to
point source dischargers, and through Load Allocations and non-regulatory programs for nonpoint
sources, to bring water quality up to standards.

C2.3 NTA 1: Whichever entity or consultant works on this should include a review of the
Page 184. Stormwater NPDES Permits (C2.2). This ongoing program description should also include
the goal (at the next permit cycle) to have full coverage of the Puget Sound basin and that the
permits include improved watershed planning and coordination (two features which are not as
strong as needed in the current draft permit).
Page 185. Stormwater NPDES requirements – near-term action (C2.2). We recommend that an
additional near-term action be added: Pass legislation to ensure long-term stable funding for
stormwater improvements. A bill for this purpose was supported by the Partnership in the last
legislative session.
Page 189. Local Pollution and Control Programs – ongoing programs (C2.4). This paragraph could be
significantly beefed up. This is an important need. For example, exterior building materials need to
be addressed, including items such as roofing material, fencing materials, and surface coatings or
paints.
Include the science needs identified in the Biennial Science Work Plan for this section. On page 192 there is a brief discussion of the science needs for stormwater, but
the identification of science needs is not consistent across the different strategies.

C2 “Use a comprehensive approach to manage urban stormwater runoff at the site and landscape scales” - The framework for this strategy is quite comprehensive and
well thought out. The six sub-strategies cover the priority work that needs to be accomplished in order to protect Puget Sound. One emphasis that should be highlighted
throughout is the greater need for incentives for stormwater work. The strategies included in C2 are comprehensive and critical to the health of our freshwater streams.
The biological target of maintained and/or enhanced macroinvertebrate community diversity is a well selected integrated metric. However, it seems optimistic that
benthic invertebrate communities will return in greater numbers to degraded habitat if we only act to remove the forcing factors that caused the degradation (i.e.,
reduced geomorphically significant flows and pollutants). The key issue here is the physical changes to the stream channel and subsequent sediment quality shifts to
habitat that is likely to repel native species. It seems that there will be some need for restoration and time in this process. The NTAs are requisite for the long term
health of basin freshwater streams. The approach outlined in C2 has 16 NTAs, four of which are local by definition (LNTA). Full or partial responsibility for NTAs falls to
local governments in eight cases; and Ecology in six cases. Although all of these NTAs are important, C2.1 NTA1 Protect excellent streams, C2.5 NTA1 Training, C2.2 NTA4
Vesting, C2.4 NTA1 Inspections, and C2.6 NTA1 Monitoring are the most critical elements.

C2.1 “Manage urban runoff at the basin and watershed scale” - The emphasis on protection of native vegetation and proper siting for new development is useful;
however, there seems to be no mechanism for promoting these smart growth concepts besides providing new information. Smart compact planning and restoration are
typically at odds with other competing needs (financial, resistance to change, etc.). Strong incentivizing will be necessary to change the paradigm to sustainable growth.

C2.1, NTA 1 - This NTA seems to defer to King County to develop a NTA for protection of healthy streams, as it states they should “develop an overall strategy and
tailored actions to protect these areas.” The strategies and actions are undefined in the current form.

C2.1, NTA 2 - There is currently no lead to lead the coordinated mapping effort. I suggest Ecology could be a good clearinghouse for such information but am hesitant to
recommend them to take the lead on the protocol/methodology work; they have substantial responsibilities for the other C2 NTAs.

C2.2 – ‘Prevent problems from new development at the site and subdivision scale’ - Critical elements include the expansion of NPDES MS4 permit coverage, seek funding
for local governments, and ordinance scrubbing/greening to accommodate/promote LID. EPA is charged with the responsibility to “…ensure permits for federal and tribal
lands/facilities are consistent with state-issued permits…” however it is unclear what mechanism could be used to ensure new development outside of MS4 permitted
areas also includes current stormwater management standards.

C2.2 Stormwater NPDES Permits (page 184) - The best way to improve NPDES permits is to make sure there is good communication with other programs. An NPDES
permit must translate the waste load allocation from a TMDL. It is the waste load allocation from TMDL that helps control stormwater and it can also help in
enforcement because it holds the permittees to a certain standard. Include LID outreach to consulting firms and professional associations because often the decision to
use LID is in their hands.

C2.2, NTA 2 - The timing of this treatment standard evaluation ensures that it will not be adopted until the next permit cycle starting in 2017. It is doubtful that such
changes will make meaningful progress for the 2020 targets in time.

C2.2, NTA3 – Specify how large these shellfish areas will be, how the shellfish areas be prioritized, and which agency will make the decision.

C2.2, NTA 4 - Vesting is a critical element for ensuring success for existing standards and management.

C2.2, LNTA 5 - A performance measure needs to be defined for this action.

C2.3 ‘Fix problems caused by existing development’ – This strategy includes retrofit prioritization and maintenance to address legacy contaminants.

C2.3, NTA 2 – This NTA has similar flaws to C2.1 NTA1 (i.e. charges King County with developing strategies and actions to improve stream health status as measured by
macroinvertebrate diversity).


Strategy C2 focuses on urban stormwater runoff; however, the stormwater challenges described in
this section are not limited to urban basins. In particular, Strategy C2.1 focuses on maintaining
stream health in locations where streams have “excellent” biotic integrity scores. Theses streams,
with excellent biotic health, are for the most part not located in urban settings. In order to maintain
the health of these systems, the stormwater strategies should be expanded to include a rural focus
as well.
• It should be highlighted that several (perhaps most) of the NTAs cannot be completed without
additional or adequate resources. For example, this is the case for two sound-wide actions that King
County has been identified as owner: to identify and map BIBI scores for streams (NTA 2.1.1 and
2.3.2). King County has expertise to accomplish this type of task, but does not currently have the
resources to accomplish this. This example begs the question of how many NTAs are in fact
achievable given current resource commitments. This is an overall concern for all of the NTAs; the
overall cost of Action Agenda implementation has not been presented. Without some additional
information about the cost of these actions it will be difficult to understand and prioritize them.
• We recommend adding language to NTA 1 under C2.5 regarding stormwater education to support
a role for community colleges, for example: “support local community colleges to develop
interdisciplinary curriculum and degree programs related to stormwater management that include
law; ecosystem processes; engineering; and leadership skills to work effectively with diverse
stakeholders.”
• In the discussion of stormwater (page 182), there should be a recognition that stormwater
management is also addressed outside of NPDES permits, including other tools such as the Growth
Management Act and the Shoreline Management Act. It is appropriate that stormwater concerns
receive more attention in these processes to foster stormwater management on a regional or basin
Strategy C.2.2, NTA 4:
We strongly disagree with expending any resources on a study of current state vesting laws. Vesting
rights are well established in Washington law, and our limited resources for protecting and restoring
Puget Sound would be far better spent elsewhere, such as advancing priority retrofit projects. This
topic has no place in the Action Agenda. This
NTA should be eliminated.
NTAs we support:
In MBA’s view, the highest priority for stormwater should be fixing problems caused by existing
development built before today’s stormwater rules and flow control standards were in place. The
first step is identifying priority retrofit projects; therefore, we support Strategy C.2.3, NTA 1.
Given the current desire to reduce the amount of NTAs, State Parks will not be proposing any new
NTAs. However, it appears from the available draft documents that actions that State Parks has the
capacity to track for performance measurement are largely included within the existing NTA
framework and could be addressed through existing NTAs. These items include:

•Outreach/Interpretation can be addressed through C2.5 NTA 1

additional activities that are easily tracked for Parks and may be addressed by existing NTAs are:

•Stormwater Upgrades – in the old action agenda this was addressed as NTA C.3N2.3
Stormwater Management
The Action Agenda includes some recommendations on addressing polluted runoff from lands and
facilities. Those recommendations could be improved by focusing on the most critical limiting factor
of highly functioning municipal stormwater controls: lack of federal and state financial support. The
Action Agenda recognizes that “Current investments by local governments in municipal NPDES
permit programs far exceed state and federal-level investments…” (pages 184-186) and cites the
Partnership’s Stormwater Needs Assessment and Ecosystem Coordination Board Stormwater
Committee. The Stormwater Committee concluded that local governments were funding over 90%
of municipal stormwater work and recommended a significant increase in state and federal
contribution to achieve a more balanced level to protect Puget Sound as a regional and national
treasure. (Report of the Stormwater Subcommittee of the Ecosystem Coordination Board,
Stormwater Policy Statements, April 1, 2011). This deficit drives current approaches to controlling
polluted runoff. It is exacerbated by the Partnership’s Stormwater Needs Assessment estimate of
“…the cost to retrofit existing development for treatment alone is estimated to cost, at a minimum,
$3–16 billion.”

The Ecosystem Coordination Board found the lack of state and federal financial support to municipal
stormwater management to be so critical that “…given that runoff is a major contributor of pollution
to Puget Sound, without a significant increase in stormwater funding in 2012 and beyond, the
Role of the Puget Sound Regional Council. PSRC is listed in the draft Action Agenda in relationship to
C2.3 NTA 1, on pages 188 and 495, the Near Term Action to complete a Transportation Stormwater
Retrofit Program for the central Puget Sound. This work is critical to the restoration of Puget Sound
but has not been adequately funded and there is no current timetable for the work. The Action
Agenda should reflect an up-to-date set of expectations with regard to both funding and timing. It
would be unfortunate for expectations to be raised of PSRC that do not also reflect the priorities of
the entities that control the funding sources needed to accomplish this important work.

NTA C.2.2 would prevent problems from new development at the site and subdivision scale. The City
of Renton strongly supports this NTA. State funding will need to be increased significantly if the draft
NPDES Municipal Stormwater Permit requirements become final as proposed.

NTA C2.3 would correct problems caused by existing development (structural upgrades,regular and
enhanced maintenance). We support retrofit projects provided that there is a funding source to
absorb the added cost.

NTA C.2.5 would provide focused stormwater-related education and training. The requirements for
LIDs are significant issues that are proposed as a mandatory requirement in the Draft NPDES
Municipal Stormwater Permit, which is currently being reviewed and scheduled for finalization in July
2012. We support more training and evaluation of LID requirements for local governments and
developers, engineers and property owners before such requirements are made mandatory in the
NPDES Municipal Stormwater Permits.
C2.2: In order to ensure a reduction in urban stormwater runoff and a transition to LID
implementation in the Puget Sound area, a long-term and stable funding source will be necessary.
Establishing long-term state funding for these projects will be essential for long-term success. (p. 183-
86)
- Evaluate the need to bring in all Puget Sound coastal cities with populations over 5,000 for
coverage under the municipal stormwater discharge permit, not just cities over 10,000. Many of
these cities are contiguous and/or expanding rapidly, and have big impacts to stormwater. (p. 184)
C2.4: The "inspections and enforcement" section does not mention enforcement. We suggest
increasing funding for enforcement, especially for repeated pollution incidents. In addition, we
would like the fines for enforcement to be scaled such that they function as deterrent s, not as the
mere “cost of doing business.” (p. 189)
- For TMDLs we suggest increasing follow-up work to ensure water quality goals are met, including in
future years. (p. 189)
C2.6: In order to ensure the integrity of the policies mentioned in this strategy, such as NPDES,
adequate funding needs to be available for enforcement. Without increased inspection and
enforcement, the NPDES Permits permits, for example, may not reflect an increase of protections
C2.2 Stormwater number of NPDES
Comment: This makes us nervous as its unclear the basis for which pollutants would be selected at
which levels. The science isn’t there that directly links discharge levels to 2020 recovery targets.
Sounds good and maybe additional detail about what is being proposed would help. But overall I’m
not sure standards for who and for what and how it would be determined would be done. It sounds
like this is for new/redevelopment and Ecology is already pursuing LID standards for this – is this in
addition? Just not sure this is well thought out.

C2.3 NTA1 Fix problems caused by existing development
Comment: Once again, seems like a pretty ambitious project. Is PSRC is the appropriate entity to do
this work? A list of top projects almost certainly won’t be available by Dec 2012. The KC/EPA work
referred to is rough at best and geared really only toward flow. It’s not a strong basis of developing a
prioritized list. Also, who will fund this effort?

C2.5 NTA 1 Stormwater-related education and training
Comment: Highly supportive of Washington Stormwater Center.

C2.1 Manage urban runoff at the basin and watershed scale

Although the use of Watershed Characterization efforts are important to help prioritize restoration
efforts, it is vital that they not trump treaty obligations by the state. Restoration efforts should not
be limited in areas that may be recognized as suitable for development if those areas are needed to
provide necessary habitat to meet those treaty obligations. The Stillaguamish Tribe compels the
Partnership to ensure Watershed Characterization efforts are not favored in places that directly
impact treaty rights.

C2.3 Fix problems caused by existing development

We encourage the Partnership to help promote and work towards the development of stormwater
systems that can address emerging contaminants that can be harmful to aquatic life, and especially
ESA listed salmon. Please see comments under C1.

C2.5 Provide focused stormwater-related education and training

We are particularly concerned about homeowner associations (HOA) that have onsite stormwater
systems. As subdivisions are becoming more prevalent in our watershed, so too are retention ponds
and other onsite stormwater systems designed to treat and store surface water runoff from
Page 190, under Key Ongoing Program Activities, in first sentence of first paragraph insert after local governments, “Washington Sea Gran



The AA has a tremendous focus on urban issues. The AA also needs to address rural issues, especially
related to runoff. (See section C 2). Clearly there are urban stormwater issues that are not issues in
rural areas; however there are key issues with rural runoff, such as flooding and stream aggradation,
which are not adequately addressed.
Strategy C, subtask 2.4
Control sources of pollutants

NTA #3
San Juan County Public Works will convene Community Development and Planning Department
(CDPD), Department of Health and Community Services (DHCS), and the San Juan Islands
Conservation District (CD) to identify and coordinate best management practices for stormwater, on-
site septic systems, and animal wastes with community participation by 2013. CDPD, DHCS, CD, and
the Town of Friday Harbor will publicize information by the second quarter of 2014 at the DHCS,
CDPD, and Town permit counters and associated websites, with a goal to target 100% of applicants
by the end of 2014. San Juan County will provide for identified best management practices in County
Code by 2014.

WSCC Comment: Support
Strait of Juan de Fuca Action Area:
- We see that implementation of the WRIA 17 instream flow rule is one of the top six priorities for
the Strait. While the EJWC does not implement the rule per se, we do include identifying mitigation
strategies and projects for instream flows as one of our top priorities. EJWC is the only group working
on mitigation projects for instream flows in WRIA 17, but our funding ends on June 30, 2012. To
make this priority a reality, additional funding is needed quickly to sustain EJWC and allow it to
conduct projects.
- Similarly, we support the ERN’s identification of the need to build local capacity of the ERN and its
member organizations to function effectively and work toward recovery.
- We are pleased that the ERN included implementing our Detailed Implementation Plan as a
strategic priority. As noted above, implementation will cease on June 30, 2012, without new funding.
- On page 403, in the entry for Instream Flow Rules in the “Packaged” Priority NTAs table, please
change the bullet regarding WRIA 17 to “Implement WRIA 17 Instream Flow and Water Management
Rule.” The Rule was adopted on December 31, 2009.
Local Action Agenda in the Strait of Juan de Fuca (page 396) Further work is required to complete
this section of the PSP Action Agenda. The Strait Ecosystem Recovery Network proposes a lengthy
suite of strategic priorities and priority NTAs extensively linked to PSP's recovery targets.
Terminology about packaged NTAs intermingles with strategic priorities and priority actions, making
it challenging to discern, review and critique individual elements. Some questions that come to mind:

• ID#6 -- What does monitoring entail? Enumeration, fish health assessment and population
dynamics? What are the habitat restoration projects?
• ID#18 -- What is included in the North Olympia Peninsula's LE 3 year work plan? What is LE? Does
the workplan include the Elwha revegetation project, Dungeness River floodplain restoration and
Elwha ELJs? What is an ELJ? What is included in the Hood Canal Coordinating Council's LE 3 year
work plan?
• ID#15 – We are encouraged to see transboundary coordination on oil spills as a packaged priority
NTA. However, the difference between "support transboundary coordination on oil spills" and
"participate on cross partnership oil spill workgroup" is unclear. What action is associated with
Geographic Response Plans data and are these specific to oil spills or all environmental emergencies
within the area? What is the work to expand drills along the Strait of Juan de Fuca and coast?
• Although prioritized and sequenced, the assignment of actions and accountability are not
addressed.
• Designation of Protection Island Aquatic reserve should be acknowledged as a context for
management if not a notable accomplishment.
• We recommend the creation of a network of marine reserves to recover rockfish species as
identified in the state rockfish conservation and management plan and the Action Agenda more
broadly. This is particularly necessary in this action area because of the diversity and viability of
extant stocks of rockfish necessary to repopulate the rest of Puget Sound.
• Strait of Juan de Fuca would receive special benefit from permanently protecting wildlands and
headwaters on the Olympic Peninsula. Please see our comments on special designations which
encourage the Partnership to support Congressman Norm Dicks and Senator Patty Murray’s
Wilderness and Wild & Scenic River designations.
Progress ha been made in fulfilling several of the key goals initially identified for the Strait ERN Strategic Priority
Oil pill Prevention Preparedness and Response (Strategic Priority ID#15) including most significantly the
permanent stationing of the Neah Bay Response tug. In addition, theStrait ERN ha gained a presence in several
committees identified through the Makah Tribe's appointment to the RRT/NWAC, Cross partnership oil
spill workgroup (along with Clallam County Commissioner Doherty) as well as the oil spill
advisory group established by Ecology to oversee the rulemaking required by SB 1186.

This representation also furthers the previously identified goals of establishing a liaison role for the Strait ERN
during a spill for the Makah, being on the RRT, are notified if an incident command is being stood up in the
region and has been trained to serve in the Command. As part of this training, the Makah have participated in
CANUSPAC exercises along the Strait and Coast and was instrumental in calling for the update of the oil spill
capability across the boarder in the US Coast Guard Reauthorization.

While this furthered the call for improved trans-boundary coordination on oil spills in the original priorities, this
item, which specifically calls for tribal participation, remain a priority for this biennium as we expect this update
to occur during this time.

There are ongoing needs to assure that GRPs are updated and groundtruthed. This is best accomplished through
a rigorous drill program that also furthers the goals of improving the incorporation of vessels of opportunity and
volunteers as called for in SB 1186. It is hoped that the existing GRPs are being incorporated into the update of
the Shoreline Master Plans underway, and visa versa, but will also need ongoing review. Other ongoing needs
include continued funding for HAZWOPER, Incident Command System and Oiled Wildlife classes for volunteers
from across the Strait Action Area, historically sponsored by the Clallam Marine Resource Committee (MRC) in
cooperation with the Jefferson MRC. Continued support for the publicly funded oil spill response equipment
caches that are strategically located throughout the Strait Action Area, and funding for routine training in the
use of that equipment is also needed. This leaves the three highest priority specific actions for this Biennium's
Strait of Juan de Fuca Action Area

Staff from the Jamestown S’Klallam Tribe (JKT) and Port Gamble S’Klallam Tribe (PGT) and PNPTC
regularly attended and participated in the development of actions for the Straits Action Area for
inclusion in the Puget Sound Action Agenda. The Strait Ecosystem Recovery Network (ERN), as Lead
Integrating Organization (LIO) for the Straits Action Area, will be submitting comments on the draft
2012 Action Agenda. We contributed to and fully support the comments submitted by the Strait
ERN; hence, we will not repeat them here.
We, the undersigned, members of but not speaking on behalf of the Strait of Juan de Fuca Ecosystem
Recovery Network (Strait ERN),do not support one Stormwater sub action of the Strait Action Area’s
sixth "packaged" near term actions earlier submitted to the Partnership as part of the update
information. The unsupportable piece is "City of Port Angeles CSO Reduction Stormwater
Management Program Update and Projects - CSO Phase 1 Projects - Implement suite of projects to
reduce CSO overflow events into the Port Angeles Harbor to one per outfall per year on average."
(Emphasis ours)

Having reconsidered how stormwater is currently proposed to be handled by the City, we feel "City
of Port Angeles CSO Reduction Stormwater Management Program Update and Projects - CSO Phase
1 Projects - Implement suite of projects to reduce CSO overflow events into the Port Angeles Harbor
to one per outfall per year on average" is counter productive to the goals of the Puget Sound
Partnership for restoration of the Sound/Strait.

Whereas CSOs continue to cause stormwater overflows,

Whereas the City of Port Angeles has in place a near citywide stormwater system separate from its
sewer system and that these systems should be repaired and expanded to help eliminate overflows,

Whereas on site source separation, low impact development, and other green methods beneficially
clean stormwater and recharge our needed water supply – increasing the aquifers and other
stormwater reuse methods,

Whereas aquifer recharge and stormwater reuse is gaining rapid importance with increasing global
warming for both natural resource, wildlife and human needs,

Whereas green methods can increase the attractiveness of properties, neighborhoods and
page 396 - Profile
Suggestion: Add reference to Clallam and Jefferson counties and the Olympic National Forest to this
sentence: “It is home to the Makah, Lower Elwha Klallam and Jamestown SKlallam Nations and tribal
reservations, Clallam and Jefferson counties, and the cities of Port Townsend, Port Angeles, and
Sequim, and much of Olympic National Park and Olympic National Forest.”

page 396-397 - Port Angeles Mill reference
Suggestion: Actually, the largest mill within the Strait Action Area is a paper mill, not a lumber mill.
We suggest making the following changes to the text: “In other places, commercial timber harvest
remains an important economic sector, supporting an active paper mill in Port Angeles.

page 397 - Notable Accomplishments insert
Suggestion: Correct the spelling for the Pysht River, not Pshyt. Also, eliminate the errant spaces
within this sentence.

page 397-398 - Elwha River reference
Suggestion: Change this sentence to the following: “The largest dam removal project in US history
will reopen more than 70 miles of mostly pristine spawning and rearing habitat in the Elwha River
and its tributaries.”

page 398 - Local Action Agenda Process
Suggestion: Correct the typographical error: “...undertook an extensive... Change Request: Change
the text within the last sentence of this paragraph to read the following "Using the threats as an
internal guide, the
Strait ERN identified...".

Key Threats/Pressures
Change Request: As agreed by the Strait ERN at their June 6, 2011 quarterly meeting, ranked local
threats were to only be used internally by the Strait ERN as a guide and not considered absolute,
hence they should
Clearly identify and articulate three strategic initiatives. The these threats can may be the three
not be specifically cited here in ranked format. Alternatively,examples providedand should only beto
initiate the results desired and to develop a record of success so that future funding will not be in
question, e.g., Chesapeake Bay Program experience. There needs to be a move away from silo
planning/program approaches to a joint planning/integrated project development system. For
example, one strategic initiative is the prevention of water pollution from urban storm water runoff.
The current draft lists numerous near action tasks, many ongoing, and it is difficult to see how the
integration of these efforts will achieve the desired result.
Strategic Initiatives

We support the concept that the Action Agenda needs Strategic Initiatives which focus recovery efforts during
the next two years. Further, we agree that the Strategic Initiatives should focus on the protection of ecosystem
components. The effective implementation of the three Strategic Initiatives proposed in the draft Action Agenda
now, namely (1) protection of habitat in support of salmon recovery, (2) prevention of water pollution from
urban stormwater runoff, and (3) protection of water quality and nearshore habitat from rural and agricultural
runoff, would substantially advance the recovery of Puget Sound.

Many of the LNTAs identified for the Straits and Hood Canal Action Areas would fit well under the Strategic
Initiatives. Examples for the Straits Action Area have been provided by the Strait ERN in separate comments to
the Partnership. For the Hood Canal Action Area, some examples are listed below by Strategic Initiative:

 Protection of habitat in support of salmon recovery
• Update Kitsap and Mason County and City of Bremerton Shoreline Master Plans
• Implement and enforce existing regulatory programs of the counties (SMP, CAO, County Comp.) and State
(RCW’s and WAC’s)
• Permanently protect larger tracts of forests for their forest (ecological and community) values – e.g., Port
Gamble/North Kitsap, Dabob Bay, Stavis
• Protect, foster and incentivize sustainable working forests and farms
• Implement 3-year habitat/harvest/hatchery work plans for salmon recovery
• Implement comprehensive floodplain management plans where they exist
• Work with WRIA Planning Units to implement priority actions

Prevention of water pollution from urban stormwater runoff
• Revision of development code to incorporate current stormwater management practices – specifically,
adoption/implementation of most current Ecology stormwater manual
• Implementation of Pollution Identification and Control (PIC) programs
• Adoption of low impact development (LID) practices
• Prioritization of stormwater retrofits
• Retention of natural land cover as the most effective way to prevent stormwater runoff

Protection of water quality and nearshore habitat from rural and agricultural runoff
• Develop and implement a regional ambient monitoring program for the streams and shorelines of Hood Canal
C1.1 - NTA 3: Water Quality and Sediment Standards Updates: The Northwest Indian Fisheries
Commission and several tribes in the Puget Sound region (and other areas of the state) are
examining existing information on fish consumption and in 2012 will provide recommendations to
Ecology on tribal consumption rates to support the revisions to the standards. In 2012, Ecology plans
to revise the state’s sediment quality standards and begin the process to revise the water quality
standards to reflect up-to-date information about rates of fish and shellfish consumption in
Washington.

Although the Department of Ecology is working with the Northwest Indian Fisheries Commission and
tribes in Washington to review the current fish consumption rates, it is premature for the
Partnership to make any recommendations or provide a near-term action that relies on the
completion of such work. For example, Ecology just recently announced a three month delay in the
work to review the fish consumption rates. The real question for
the Partnership to ask is: do current water quality and sediment management standards protect the
Puget Sound? And if not, where and how do we need to feel the gaps?

The near-term action on fish consumption rates also raises a question about the Partnerships
C1.4, NTA 1:
BIAW opposes the establishment of a landscaper certification program, let alone opening the door to
possibility it may be required. Landscapers must already comply with a “laundry list” of rules and
regulations governing the application of fertilizer and pesticides. A water auditor certification
program is already in place; this new certification program is duplicative and places an unnecessary
burden on the landscaping industry.




• Task 1.1, multiple actions to remove toxic sources. Staff supports processes that reduce toxics at
the source, rather than trying to deal with them under other permits, which may not be technically
feasible.
• Near Term Action 6 - toxics monitoring. Staff question whether this action is duplicating elements
currently being proposed in the Phase I and II municipal stormwater permits?

Page 169
At an Ecosystem Coordination Board meeting in 2009, the Director of the Department of Ecology
stated that putting in place a phase-out of mixing zones for persistent bioaccumulative toxics was
one of three big priority changes in policy that would significantly benefit Puget Sound. DNR agrees.
Toxics are extremely expensive to remove from the ecosystem once they are in. Prevention is the
most efficient and effective approach, and phasing out mixing zones for PBTs would generate
process changes that amount to prevention. DNR encourages PSP to include an NTA in C1.1 "Reduce
the sources of toxic chemicals entering Puget Sound" to set a schedule for the phasing out of mixing
zones for PBTs.

Page 175
An NTA should be added to require product labeling identifying the specific toxics present in a
product so that consumers can make informed purchase decisions.
p. 168 - Some overlap with C2.4 (control sources of pollutants), specifically with dissolved metals
from brake friction material. ‘Legislation recently signed into law in Washington prohibits brake
friction material containing asbestiform fibers, cadmium and its compounds, chromium (VI) salts,
lead and its compounds, and mercury and its compounds, from being sold in state by 2014. By 2021,
no brake friction material will be sold or offered for sale which contains more than 5 percent copper
and its compounds by weight. While Washington State does not provide a specific deadline, the state
also bans the sale of brake friction material exceeding 0.5 percent copper by weight once a proven
and safe alternative replacement material is identified.’ Maybe put in NTA for 2014 requirement,
either here or in C2.4?

p. 168-169 - General Comment - put deadlines in performance measures – only NTA 4 has one.

p.169 - C1.1 NTA 3 - DOH Office of Environmental Health, Safety and Toxicology (OEHST) should be
included in the revision of water quality standards to reflect up-to-date information about fish and
shellfish consumption rates.

p.176, C1.5 NTA 1 - Don’t some localities have hazmat compliance work? Shouldn’t they be
mentioned as well as Ecology? Description in ‘Ongoing Programs’ section should be moved here. For
example:
NTA 1 – in FY2012 conduct 345 compliance inspections…
NTA 2 – in FY 2013 conduct 410 compliance inspections…
NTA 3 – Respond to and close out…
Except parse out ‘PS only’ targets (statewide targets listed in ongoing programs)

p.165, para 2 - Ecology has evaluated 17 chemicals of concern (COC) as part of a toxic loading study.
The paragraph makes a statement about additional emerging contaminants, which will be important
to evaluate in terms of toxic threats to biota and to humans through seafood exposure. Note that
there may be additional COC beyond those studied that may be of ecosystem and human health
concern.

p.166., para 4. - This paragraph Chemicals recovery targets, including ensuring that “endocrine-
C1 Reduce the Sources of Toxic lists specific
C1. 4 EJWC supports education and technical assistance to homeowners, businesses, and others to
prevent and reduce toxic releases.
C1: Reduce Toxics
General comments:
- We appreciate that many of Ecology suggestions that were incorporated into the draft, particularly those that
relate to Ecology’s Hazardous Waste and Toxics Reduction Program work. Overall, we are pleased with the
added emphasis of toxics in the draft and support the overall direction to implement and strengthen authorities
and programs to prevent toxic chemicals from entering Puget Sound.
- With regard to air emissions, Ecology is generally supportive of the language expressed in the draft.
- The Puget Sound Toxics Loading study is rightfully mentioned (i.e., “the findings from this assessment are
summarized in chapter of the Action Agenda addressing Question 2, what is the status of Puget Sound?” ). Yet, a
summary is not in the Action Agenda. Suggest providing highlights from the study.
- Ecology should look broadly at chemicals of concern (COCs). The 17 COCs in the Toxic Loading Studies are
neither the only COCs in Puget Sound nor necessarily the most important. Ecology should look at what we
learned from the Toxics Loading Studies and other research to target more COCs are that are important. This
would include both emerging as well as the better understood COCs.
- Ecology should do more to reduce PBTs, especially since the Toxics Loading Study highlighted the priority of the
PBTs among the 17 COCs. Ecology’s current strategy of preparing and implementing CAPs for one PBT at a time
may not be sufficient for Puget Sound. Ecology could specifically work on multiple PBTs in Puget Sound using the
existing PBT list or an expanded PBT list. The region could seek more authority to reduce PBTs in Puget Sound.
- Green Chemistry and alternatives assessment are important for reducing the use of chemicals. In addition to
voluntary actions, the region should seek authority to require alternative assessments for the highest priority
chemicals in Puget Sound.

“The Challenge”: page 165, second paragraph, fourth line; suggested edits: Of the 17 chemicals, only five have
been banned restricted nation-wide under the federal Toxics Substances Control Act (TSCA).”
The Challenge”: page 165; suggested new language: “PBTs raise special challenges because they remain in the
environment for a long time and accumulate in people and in the food chain. They also can travel long distances
and generally move easily between air, land and water. Prevention is especially important for PBTs, since they
can remain in the environment and continue to harm wildlife. One example is PCBs, which were banned more
than 30 years ago, but remain in the environment and continue to harm wildlife and people. Because of the
special challenges of PBTs, Washington created a unique program to specifically address PBTs through the PBT
Page 168. Toxics reduction – near-term actions (C1.1). Most of the near-term actions listed for this
strategy are already planned to occur. Therefore, we recommend that they be shifted to “ongoing
programs.” The monitoring near-term action should be removed from this strategy or a similar
monitoring action should be included for all strategies in the Action Agenda.
Page 168. Toxics reduction – needed near-term actions (C1.1).
• A “change agenda” near-term action would be for Ecology or the Partnership to evaluate the
results of the Toxics Loadings studies and develop a workplan for reducing the priority toxic
chemicals.
• A second “change agenda” near-term action – and this would match the title of this action – would
be to enact chemicals policy reform at the state level.
Page 172. Missing action – reducing toxics from wastewater. Action C1.2 (Adopt and implement
plans and control strategies to reduce toxic releases into the Puget Sound from air emissions.) is an
excellent action. The Action Agenda is missing a parallel action for wastewater discharges, specifically
industrial wastewater discharges. Although Actions C xx below addresses wastewater discharges, it
would be clearer for the reader if a toxics-related action (parallel to C1.2) were included here (and
included a soft reference to C xx below). It is appropriate that it be in this strategy (there are
Consider a separate NTA for emerging contaminants (NTA in C.1. The NTA would be taken from the “Emerging Issues and
Future Opportunities” on page 176, first bullet). The need to better understand these contaminants is referenced in several
sections (e.g., pages 176, 178, 224, and 229). This is a large task, but it will continue to be raised as a need. “Key Ongoing
Program Activities” could be merged into the “Ongoing Programs”. It is also not clear how the “Key Ongoing Program
Activities” were selected.

C.1 - A logic chain is needed for this strategy. This will help clarify how the sub-strategies fit into the overall strategy. For
consistency and accountability, include a lead for each of the NTAs as in

C.1.1 NTA 3, NTA5 and NTA 6. For example C1.1 NTA 1 could have a lead for “Chemical Action Plans” and C1.1 NTA could have
a lead for “Non-agricultural Use of Copper-based Pesticides”.
On page164, change the title for strategy C1 to “Prevent, Reduce, and Control the Sources of Toxic Chemicals Entering Puget
Sound”. We think it is important to have “Prevent” in the title.
In the first paragraph of page 167, include any specific actions Ecology has taken to help modify TSCA.
It is not clear how the Key Ongoing Program Activities on page 168 were selected. There are numerous other on-going
activities (all the NEP funded projects, CAP related activities) that could be included. Consider integrating this section into the
“Ongoing Programs”.

C1.1, NTA 2 (page 168) - Additional detail on the program would be helpful, including whether this an extension of an existing
program and who Ecology will work with.

C1.1, NTA 3 (page 169) - Include revisions of standards based on updated toxicity and BAF information as well as fish
consumption. This information may have also changed.

C1.1, NTA 4 (page 169) - Add a sentence on how this information will be used and whether this could lead to changes in
labeling requirements or a public education program.

C1.1, NTA 5 (page 169) - Clarify whether this action applies only to residential use pesticides. The performance measure
involves identification of options to limit the use of copper-based pesticides in residential use, but this effort should be for all
applications not just residential uses.

C1.1, NTA 6 (page169) - Since the specific tasks (1-3) are still being discussed, the Partnership may not want to include them in
this NTA yet. The action could mention that the monitoring program will build on existing programs (e.g. “PSP and the
agencies involved in toxics source reduction programs….local jurisdictions – will build on the existing monitoring to develop a
….).

C1.1, NTA 7 (suggested new NTA) - Transboundary Collaboration: PSP, Ecology and EPA will work with Environment Canada
Near term action items:
C1.1 – The Washington State Department of Agriculture will assemble data on non-agricultural uses of copper-based
pesticides in Washington based on changes in registration status of cooper containing pesticides and comparing use patterns
in Washington and California. This will begin with estimates of urban landscape/homeowner use and will expand to
commercial applicators. By Dec. 2012, WSDA will report estimates of urban landscape/homeowner uses of copper in the
Puget Sound region.

C1.1 - Alternatives to copper in pesticides: Ecology and WSDA will evaluate alternatives to copper in pesticides to identify
whether safe alternatives are available and commercially viable. Based on the alternatives analysis results, the agencies will
explore options to limit the use of copper-based pesticides, if better alternatives are available.

C1.4 - Landscaper Certification: By 2013, Ecology will work with the Washington Department of Agriculture, business
associations, and other stakeholders, to establish a landscaper certification program to promote environmentally friendly
landscape development and maintenance practices. The program would be designed to improve habitat and water quality by
reducing the use of pesticides containing toxic chemicals, reducing the use of fertilizers, reducing the use of water for
irrigation, reducing runoff from landscaped properties, and reducing emission form landscape equipment.

Selection of landscape uses of copper as a focal point for regulation
It is our understanding that the Washington State Department of Agriculture has expressed concerns about C1.1. Based on
the data, they do not believe these actions are necessary or a wise use of state resources. The loading numbers for copper
from pesticides in the report do not fit actual monitoring data. Based on the products registered for use, it would be
impossible to get loading numbers that high from landscape uses.

Copper is an important fungicide for lawn and landscapes as well as agriculture. It is the primary fungicide used in organic
production and organic landscape care.

The report lists copper as a major contaminant of Puget Sound even though levels detected in marine waters are orders of
magnitude below EPA benchmarks for marine aquatics. Based on the data in the report, it does not appear that copper is a
problem or that source controls are warranted.

The Department of Ecology report used in the development of the Puget Sound plan shows the highest concentrations of
toxics were in areas zoned industrial. Residential areas were mentioned only rarely, just once in relation to copper with
respect to storm events. Only eleven detections had copper that exceed Washington’s allowable limits. These occurred
primarily in industrial areas. One, out of thirty, baseline data points had copper that exceeded limits. Higher copper during
storm events is expected since copper is a main component of brake linings and a storm event would move particles from
streets to streams. Loading of copper during storm events was substantially higher for industrial areas than residential.
re strategy C, subtask 1.1, NTA # 1.
This describes work by Ecology to complete a PAH Chemical Action Plan by 2012, and a CAP for PFOs or all PFCs
by 2013. The following should be added:
Identify where reductions have benefit and where they are not needed. The reason behind this is blanket
reductions for reduction sake are not always needed or beneficial. For example, use of creosote on telephone
poles has much less potential for impacts from PAHs than use of creosote on pier pilings in waterbodies.

re strategy C, subtask 1.1, NTA #3.
This pertains to water quality standards and sediment standards updates to reflect higher fish consumption
rates. It presumes that revisions to the standards will be required, and the performance measure would show a
failure to perform this if the standards were not revised. This pre-judges an outcome, and should not. It is
possible that our current criteria for human health are protective. For human health water quality criteria, EPA’s
guidance calls for protecting the average consumer to the 10-6 or 10-5 cancer risk level, as long as it is also
protective of the high consumer at least to the 10-4 cancer risk level. The guidance is also focused on freshwater
and estuarine fish, not all fish. It’s possible that our existing criteria may meet EPA’s requirements. It does not
make sense to protect high consumers at the 10-6 risk level. A recommended change to the NTA description
follows: Water Quality and Sediment Standards Updates: The Northwest Indian Fisheries Commission and
several tribes in the Puget Sound region (and other areas of the state) are examining existing information on fish
consumption and in 2012 will provide recommendations to Ecology on tribal consumption rates to support the
possible revisions to the standards. In 2012, Ecology plans to revise the state’s sediment quality standards and
begin the process to revise the water quality standards to reflect up-to-date information about rates of fish and
shellfish consumption in Washington. If the existing criteria are not protective enough to meet EPA human
health guidelines, then changes to the existing criteria may be needed.

re strategy C, subtask 1.1, NTAs 4 and 5
These pertain to the Department of Agriculture assembling data on the non-agricultural use of copper-based
pesticides in Washington and also to evaluating alternatives to copper in pesticides to identify safer alternatives,
and possible limiting the use of copper-based pesticides if better alternatives are available. The problem here is
that no effort is provided to determine if the use of copper-based pesticides is actually a problem. Ecology’s
phase 3 stormwater toxics loading studies did identify higher concentrations of copper from agricultural land use
than other land uses, but the same data also showed higher hardness values and much higher dissolved organic
carbon values. Our present freshwater copper criteria are based on hardness, and most all of the agriculture
runoff data met the hardness based water quality criteria for dissolved copper. There were four samples from
Strategy C.1.4, NTA 1:
We are very concerned about the proposal to establish a landscaper certification program;
especially, if this certification is to be required. Landscapers must already comply with a myriad rules
and regulations governing the application of fertilizers and pesticides, and furthermore, a water
auditor certification program is already in place. We believe creating a brand new certification
program would be duplicative and place an unnecessary, added burden on the landscaping industry.
In lieu of creating a new certification requirement, we believe the Partnership should emphasize
public and private sector education on green landscaping practices and lawn maintenance.
In addition, we’d like to specifically comment on one significant concern we have with page 26 of the
Executive Summary (Strategy C 1.1/NTA 3), which is repeated on page 168 of the Agenda at C
1.1/NTA 3. Both sections pertain to and endorse the Department of Ecology’s Water Quality and
Sediment Management Standard updates on fish consumption rates (FCR).
Considering these standards have yet to be determined or adopted by the Department of Ecology,
we believe that it is entirely premature for the Partnership to adopt this strategy in its current Action
Agenda update and would ask that these Near Term Actions be removed.
In a February 2, 2012 letter to interested stakeholders, Department of Ecology Director Ted
Sturdevant announced a delay in both the SMS and Water Quality Standard rulemaking processes,
which will incorporate an updated FCR standard. According to Director Sturdevant, “[i]t is clear that
significant science and policy questions will need to be asked an answered in an open, transparent
manner . . . As such, Ecology will take the time needed to get it right.” It is clear that this rulemaking
process is extremely complex and will take additional time and work by the agency to accomplish.
Therefore, it is wholly inappropriate for the Partnership to adopt and updated FCR standard as part
of its Action Agenda at this time.
Moreover, as the Department of Ecology moves forward with these parallel rulemaking processes, an
p. 169
Remove reference to derelict gear in notes, there is no association between derelict fishing gear and
toxic clean up.
Given the current desire to reduce the amount of NTAs, State Parks will not be proposing any new
NTAs. However, it appears from the available draft documents that actions that State Parks has the
capacity to track for performance measurement are largely included within the existing NTA
framework and could be addressed through existing NTAs. These items include:

•Piling removal is addressed through C1.1 NTA 8


p.166 -177 - While we understand and agree with the importance of addressing nonpoint source
pollution in principle, as in C1.1, the Draft Action Agenda Update does not go far enough to address
the point source problem at a regional scale.

A People for Puget Sound study of point source discharges showed that vast amounts of chemicals,
oils and grease are being discharged every minute of every day into the Puget Sound from permitted
point source discharges, including industry and municipal treatment plants. Point source issues
would be addressed more effectively through revised permit requirements, stricter permit conditions
and enforcement, studies of new treatment and filtration technologies, and associated education
and outreach. We encourage the Puget Sound Partnership to include these strategies for addressing
point source pollution in Puget Sound.



NTA C.1.1 would implement and strengthen authorities and programs to prevent toxic chemicals
from entering the Puget Sound environment. However, this NTA doesn’t seem to account for
current monitoring programs and the proposed Regional Storm Water Monitoring Program that is a
mandatory requirement in the draft NPDES Municipal Stormwater Permits. The NTA appears to be
duplicating what is proposed in the draft NPDES Municipal Stormwater Permit. The value and
monitoring effectiveness will be questionable due to condition(s) variability and the fact that
monitoring is problematic. As proposed, Ecology has incorporated this NTA as a mandatory
requirement in the draft NPDES Stormwater Permits that requires the permit holders to fund the
program.
C1.1, NTA 3: This near term action should be amended. Add a metric that defines how the change in
fish consumption rate standards affects the water quality standard and the ingestion of toxics in fish
by tribal and non-tribal residents.
The change in standard is important, but it is not a stand-alone item. The change in standard must
effect a change. If it is too early in the process to define these subsequent changes in water quality
standards and toxics ingestion, we would appreciate an indication of when these measures will be
made and the general magnitude of change expected. (p. 169)
C1.1, NTA 4: This near term action only deals with non-agricultural use of pesticides that contain
copper. Of note, agricultural use of copper based pesticides is not addressed in the section or in the
agricultural runoff section. Likewise, other pesticides of high concern, such as the organophosphates
malathion, chlorpyrifos, and diazinon are not mentioned. Please extend this work to include
agricultural use of copper-containing pesticides. In addition, please include the pesticides malathion,
chlorpyrifos, and diazinon as these were found to be extremely disruptive to salmon. (p. 169)
 According to the National Marine Fisheries Service consultation of EPA’s registration of the
pesticides in question malathion, chloropyrifos, and diazinon “share a similar chemical structure and
act as neurotoxicants by impairing nerve cell transmission in vertebrates and invertebrates” (NMFS,
262). The study concludes that the pesticides malathion, chloropyrifos, and diazinon can significantly
impact the survival, growth, and reproductive success of listed salmon. This literature review also
highlights several studies that demonstrate the effect of malathion, chloropyrifos, and diazinon on
salmon swimming abilities and olfaction and olfactory-mediated behaviors, such as predator
Reduce and Control the Sources of Pollution to Puget Sound (C)
Overall, there is a lot here. Like other parts of the draft Action Agenda, this represents a lot of good
thinking and hard work but also a bit of the kitchen sink approach (somewhat emphasized by the #
pages in the document). Again, a challenge is that it is hard to differentiate between what is actually
occurring (somewhat done by “Ongoing Programs”) from what might likely happen vs. wish list. This
question was particularly raised when reviewing a lot of exciting and interesting items from C1
regarding product management.
C1/ C1.1 Toxics Reduction
Comment: Was intrigued and supportive of all the (potential?) Product Management work identified.
Discouraging that there were no NTAs for air deposition (#1.3) but at least it made the list. We think
there should be an action directing follow-up work to Ecology’s toxic loading studies through the
development and implementation of a work plan for reducing/appropriately replacing priority toxic
chemicals.

C1.5 Increase Compliance with and enforcement of environmental laws, regulations and permits.
Comment: We support this item, but it should apply across the board in all areas, not just as applied
to pollution action items.
C1 Reduce and control the sources of pollution to Puget Sound

There is currently no mention of the Mussel Watch Program, a 20+ year effort by NOAA and local
partners to monitor contaminants in blue mussels in Puget Sound. There are data on over 100
contaminants for a variety of sites throughout Puget Sound through the National Status and Trends:
Mussel Watch Program. These data are worth considering and are available to any agency. The
Stillaguamish Tribe encourages the Partnership to utilize this data when analyzing the trends of
contaminants in Puget Sound, and to further support this program by financially and politically
ensuring its continuation.

It is important to note that there is no way to ensure that certain contaminants are below threshold
levels if the particular threshold of impact remains unknown. The difficulty with most of the so
called "emergent contaminants" is that there are no established thresholds on which to base
regulations. Particularly when it comes to endocrine disruption, many compounds have not been
tested for this type of hormonal disturbance and for those that have, it is unknown what
concentration can trigger that effect in different organisms. We encourage the Partnership to
establish a near to mid-term action that emphasizes the scientific identification of threshold levels,
and the establishment of regulations surrounding those thresholds.

C1.1 NTA 3 ….In 2012, Ecology plans to revise the state’s sediment quality standards and begin the
Our apology is offered for the late comments, but we only recently became aware of the Draft Action
Agenda (Agenda). We applaud your very important work on this project, and that of all of the
involved agencies, environmental groups, volunteers and staff. It is a major task that must be
completed fully and successfully. Also, we offer our assistance in any way that may be helpful.
Comment 1: Our position is that a new Section C6 (Sewage Sludge), under the heading, ‘Reduce and
Control the Sources of Pollution to Puget Sound,’ should be included following Section C3
(Agricultural Runoff), C4 (Surface Runoff from Forest Lands) and C5 (Wastewater). The new Section
C6 should be titled openly as ‘Sewage Sludge,’ and it should be prepared without the assistance of
any representatives of EPA, DOE, DNR, King County Wastewater Treatment Division, or any Federal,
State or County agency or individual who is associated with wastewater treatment, biosolids or
sewage sludge. An objective and unbiased approach will strengthen the impact of the Agenda.
Our Contention: The Agenda cannot be considered as being a science-based or full-disclosure
document, so long as one of the key sources of pollution and contamination to Puget Sound, i.e.,
Sewage Sludge disposal, is not addressed as a targeted agenda item. We believe that:
• The term biosolids is a contrived euphemism for Poorly-Processed Sewage Sludge, which was
adopted primarily to address public perception, economic issues and convenience
• Sewage Sludge is costly to process, transport and eliminate properly, and therefore has been
relegated to the most cost-efficient method of disposal
• Sewage Sludge is dangerous to human and environmental health
• The land application of Sludge incites ecosystem disruption and precludes ecosystem recovery
• Wildlife populations, such as wild fish, are rendered more susceptible to infectious, immune-
dysfunction and other diseases when subjected to toxic contaminants and pollutants
• Sewage Sludge is Toxic and Hazardous Waste, and is considered as Dangerous Goods
• Puget Sound cannot recover in the presence of a continuous inflow of contaminants that originate
C1.1; NTA#6: “. . . . (2) effectiveness of strategies and actions to reduce and prevent toxic chemicals
from entering the Puget Sound environment and from affecting aquatic life.” Please consider
adding the bold text.
We request that you make similar edits throughout in the Action Agenda as necessary.
C1.4 - Landscaper Certification: By 2013, Ecology will work with the Washington Department of
Agriculture, business associations, and other stakeholders, to establish a landscaper certification
program to promote environmentally friendly landscape development and maintenance practices.
The program would be designed to improve habitat and water quality by reducing the use of
pesticides containing toxic chemicals, reducing the use of fertilizers, reducing the use of water for
irrigation, reducing runoff from landscaped properties, and reducing emission form landscape
equipment.


As Executive director of the Washington State Nursery & Landscape Association (WSNLA), I would
like to comment on this section of the proposed Agenda. The WSNLA and Washington Association of
Landscape Professionals (WALP) have been collaborating with a genuine stakeholder group to
develop a sustainable landscaper certification program since summer of 2011. The selected advisory
committee is drawn from professional practitioners, public employees, educators, horticulturists,
arborists, and growers who all have a strong interest in sustainable practices for the industry. The
group is currently analyzing several programs’ versions of best practices and evaluating them for use
WRIA 16 a Washington State set of existing laws and regulations is very important and supports the
as part ofagrees that enforcementof guidelines. If the PSP is truly interested in developing this tool,
actions in section C1.5. However this needs to be expanded to include local enforcement as well. It
also needs to address funding needs; enforcement will not happen without dedicated funds.

Toxics (copper)

C1.1 NTA 4
The Washington Department of Agriculture will assemble data on non-agricultural use of copper-
based pesticides in Washington based on changes in registration status on copper containing
pesticides and comparing and contrasting use patterns in Washington and California. This work will
begin with estimates of urban landscape/homeowner use and will expand to commercial applicators
if funding is available.

This NTA should be revised and split into two NTAs in order to accurately reflect the work WSDA is
conducting to assess copper based pesticide use:

Revised NTA:
WSDA will work with Ecology to review the assumptions used in determining the Phase 3 loading
numbers. This will involve an evaluation of the TDC Environmental report completed for the San
Francisco Bay estuary in 2004, study assumptions, and an assessment of changes in registration
status of copper containing pesticides and comparing and contrasting use patterns in Washington to
California.

Second NTA:

WSDA in partnership with USDA National Agricultural Statistics Service will conduct a pesticide use
survey of homeowners within the Puget Sound basin. The data from the survey would be used to
further refine the loading estimates for urban pesticide use (including copper compounds).

In combination, these two NTAs would further refine the estimated urban uses of pesticides in Puget
Sound.

C1.1 NTA 5
Alternatives to Copper in Pesticides: Ecology and the Washington Department of Agriculture will
We agree with the proposed strategies and targets based on Benthic Index of Biotic Integrity for
Urban Runoff. In order to better link these sections to salmon recovery, each watershed chapter of
the Puget Sound Chinook salmon recovery plan should be revisited with new information about
locations, amounts, and qualities of runoff from all human development (urban, agricultural, and
commercial forest lands). We understand the challenge involved here, as many watershed chapters
were developed before 2007, and lack the necessary information to understand and tackle this
emerging issue.
C2.6 Assess effectiveness of actions and effects on the environment

Comment: Support full implementation

C2.6 Science Needs

The following is a preliminary list of science needs that have been identified:

• Will there be any effects on groundwater (i.e., hydrology or quality) from increased infiltration of
stormwater?

Comment: Yes, directly related to use of GSI

• Do we need better treatment than basic (80 percent TSS removal) for discharges to Puget Sound?

Comment: Absolutely yes, dissolved metals and petroleum hydrocarbons primarily in urban and
transportation areas

Insects in Small Streams (pg 193) The 2020 recovery target related to urban runoff is for 100 percent
of Puget Sound lowland stream drainage areas monitored with baseline B-IBI scores of 42-46 or
better to retain these “excellent” scores and mean B-IBI scores of 30 Puget Sound lowland drainage
areas improve from “fair” to “good.” …

Comment: Conceptually, the goal is good, but poorly written. The target can be met by eliminating
monitoring in streams with low B-IBI scores. This is already occurring in some local jurisdictions,
where ambient monitoring is being eliminated in order to increase the % of monitored streams that
meet the criteria. Do not target or evaluate on the % of monitored streams.
C7.1 Include assessment of cumulative impacts in planning and permitting for centralized and
decentralized wastewater systems in comprehensive plans.

C7.1 NTA 1: Commerce, Ecology, and DOH will encourage communities to more comprehensively
provide for wastewater treatment on a watershed basis, using water budgeting tools and striving to
use all water resources available (including reclaimed water) to meet the needs of people and the
environment by aligning existing plans and planning processes to more effectively meet wastewater
treatment and management needs. This might take the form of a pilot program in a watershed that
has or will soon have a full TMDL assessment and a water cleanup plan.
Performance measure: Pilot project done or not

 p. 235 Commerce is willing to assist in this effort, but this might best be lead by Ecology, especially
with the emphasis on water resource planning. Commerce focuses complementary efforts through
its Small Communities Initiative on assisting smaller and less populated communities complete
wastewater and other infrastructure system upgrades, by working jointly with Ecology and other
agency staff. There is an opportunity for additional resources to be provided to this program if more
focus is desired in the Puget Sound basin.

C7.1 NTA 2: Commerce, Ecology and DOH will identify shoreline areas outside urban growth
boundaries where residential densities are great enough that it may be appropriate to extend
centralized wastewater collection systems and that are in close enough proximity to centralized
The following comments are offered for your consideration:

Page 211, next to last paragraph, second sentence:
Add … use devices to enhance aerobic treatment, … This will make the sentence more
comprehensive and reinforce the fact alluded to in the paragraph above that treatment in aerobic
conditions is key to efficient system performance.

Page 215, second paragraph:
It would be helpful to provide some estimate of the total annual need for system
repair/replacement. The current text suggests that the need is small. While estimates vary
depending on a number of factors, an annual failure rate of one percent is probably realistic. Thus,
based on the number of systems noted in an earlier section (more than 500,000), the annual need
should approach 5,000. In this context, the reported GMAP goal seems overly modest.

I suggest you also note that Ecology oversees funding, in addition to that funneled through LHJs, that
is directed to owners to support repairs; and note as well, that LHJs issue permits for
repairs/replacements to many owners who self-finance repair work. In total, these amount to
hundreds of annual improvements; not enough to satisfy the need, but significantly more than the
current text suggests.

Page 217, second paragraph:
Enterprise Cascadia recently changed is business name to Craft3. Please consider changing the third
sentence to: Craft3 (formerly Enterprise Cascadia)….

In the context of the comment regarding page 215 text, you may want to add the following sentence
after the one above:

This program, funded in part through the Department of Ecology, uses public and private resources
Page 228, C.6.6
Wastewater discharge to Puget Sound is a critical source of toxics, nutrients, and pathogens, and it
will grow in volume as the population around the Sound grows. It is also as significant source of
waste and inefficiency in the system, as treated wastewater could replace the use of potable water
for a number of applications. Water reclamation and reuse has significant benefits in getting
contaminants out of the Sound while also increasing the amount of water available for people and
fish. We need to greatly accelerate water reclamation and reuse, and the Partnership should take
the lead in advocating this change. As of 2010, 20 wastewater treatment facilities employed water
reclamation technologies, seven were under construction, and another 41 were planning to institute
reclamation and reuse. PSP in the Action Agenda could propose establishment of a reclamation
portfolio standard of a 20 percent reduction in wastewater discharge by 2016 and 50 percent by
2020, including a requirement that non-potable uses must be met by reclaimed water if it is
available. Obviously, moving the system quickly will take significant financial resources - it would
seem that at minimum state loan money for wastewater treatment should be conditioned to be
available only for treatment levels that allow reuse. A cap and trade system for contaminants could
be instituted to incentivize reclamation and reward entrepreneurial approaches innovative enough
to do that. There are many other strategies that could be employed to accelerate the reclamation
and reuse of wastewater and DNR strongly urges the Partnership to fully investigate how to make big
gains for Puget Sound in this area. C.6.6 should be a top priority and should be greatly expanded to
lay out the steps needed, including NTAs, to move the region to a treatment system that makes full
use of reclamation. NTA B.3.2.3 could be revised to recognize the importance of wastewater
reclamation to the outfall strategy that DNR proposes developing with partners, and it should be
receive far more emphasis that it current does in the salmon recovery section beginning on page 92.

Page 209
Please note in the last paragraph that there are about 1,000 industrial NPDES permits.

Page 221
*General - The first part of the OSS pressure reduction target is challenging (95% current with inspections). The second part (90% coverage of unsewered shorelines) is very ambitious, arguably
unrealistic. It’s uncertain how this will be accomplished and uncertain if local health jurisdictions have authority to act on it given the limits of chapter 246-272A WAC and chapter 70.118A RCW.

General - The plan should not include reporting results that are so time specific that they provide no meaningful context and are quickly dated, e.g., p 216, “In the third quarter of 2011 DOH identified
24 LOSS; of those 23 were not in compliance.”

p.209 - The Challenge, Paragraph 3: Suggest editing the first sentence to say, “Wastewater treatment plants (WWTP) are centralized facilities that use sewer collection systems to serve densely
developed areas.
p.211 - C5, Paragraph 1: Edit sentence 4 to say “Small systems. . . typically serve single family residences or combined flows from fewer than a dozen homes.”
p.214 - DOH will provide an updated MRA map when mapping results from the 12/31/11 semi-annual reporting are available.
p.215 - Paragraph 1: Edit sentence 1 to say, “The state and local OSS programs are designed to regulate the safe and appropriate use of OSS to effectively treat sewage and to protect public health and
water quality.
p.215 - Paragraph 1: Edit sentence 4 to say, “The work includes the following DOH performance measures. . . .”
p.215 - Paragraph 2: Edit sentence 6 to say, “Second, the state tracks the status of OSS inventoried, inspectedd, and fixed in marine recovery areas and and other designated sensitive areas. The target,
consistent with the Puget Sound recovery goal, is to inventory all OSS, fix all failures, and be current with inspections at 95 percent in marine recovery areas and other sensitive areas by 2020. The
target also calls on local health jurisdictions to expand these areas and programs to cover 90 percent of Puget Sound’s unsewered marine shorelines by 2020.
p.215 - C5.1 NTA1: Edit this NTA to reflect work with selected stakeholders and to clarify the target date: “DOH, in consultation with local health jurisdictions (LHJs), and other interests will evaluate
the effectiveness of the state OSS rule, identify potential changes, and outline recommendations to the State Board of Health in 2013.”
p.215 - C5.1 NTA2: Edit this NTA to say, “LHJs will work . . . to make progress on the OSS ecosystem recovery target. DOH will work with LHJs to identify successes and best practices, develop common
performance standards, and recommend approaches to improve this work.
p.215 - C5.1 NTA 3: Edit this NTA to say, “DOH will evaluate public domain OSS treatment technologies for nitrogen reduction and develop standards and guidance for their use if testing results
indicate the technologies are effective and reliable. The evaluation will be completed in 2014 and work on standards and guidance, if needed, will begin after that.”
p.216 - Performance measures for C5.1 NTA3: Edit to say, This measure is outside the scope of the research project and this version of the Action Agenda.
p.216 - C5.1 LNTA4: Three comments. (1) San Juan county indicated to DOH that the 60% target for alternative systems is countywide, not sensitive areas. (2) What does footnote 13 reference? (3)
Why try to determine a performance measure for an NTA that has built-in measures and targets?
p.216 - C 5.2 Ongoing Programs, Paragraph 1: Edit to say, “The work includes the following DOH performance measures . . .”
p.216 - C 5.2 Ongoing Programs, Paragraph 2: Suggest replacing the paragraph on the state GMAP performance measure for LOSS with the following, “The state GMAP performance measure for LOSS
is the percent of Puget Sound LOSS in compliance with state requirements. The measure has been updated to reflect the revised LOSS rule adopted by DOH in 2011. At a minimum, compliance means
the LOSS has a current operating permit and does not have an active DOH compliance action or notice, especially with respect to a drainfield failure. By the end of 2011, DOH had identified 277 LOSS
in the Puget Sound region, 263 of which were under permit. Compliance levels may drop as the new rule takes effect and all LOSS came under the program, including many previously undocumented
LOSS and LOSS formerly permitted by Ecology or local health jurisdictions that are transferring to DOH.”
p.217 - C5.3. Edit strategy to say, “Improve and expand funding options for on-site sewage systems and local OSS programs.” Without changing the focus of this strategy or the ensuing text, this edit
broadens the scope to allow consideration of all on-site sewage system (OSS & LOSS) funding needs.
p.217 - C5.3, Para 1: Check figures and edit the second sentence. It’s confusing to say “the average cost . . . can be as high as $40,000.” Seems you should either say the cost of replacing a system can
be as high as $40,000, or say the average cost of replacing a system is approximately $____.
p.217 - C5.3, Para 2: Change Enterprise Cascadia’s name to Craft3. I confirmed this name change with Terry Hull.
p.217 - C5.3, Para 2: Suggest editing sentence four to say, “. . . and Clallam Counties to repair or replace on-site sewage systems”
p.217 - C5.3, Para 2: Suggest editing the final sentence to say, “Additional and more reliable sources of funding are needed to support local O & M programs and to repair or replace failing on-site
sewage systems.
p.217 - C5.3 NTA1, Performance Measures: The action says the agencies will evaluate options and support proposals. As such, the performance measure should start with, “evaluation completed or
not.” It may make sense to leave in “coverage of loan program” and “capitalization of loan program,” assuming something actually emerges. Numbers of homeowners assisted and improvements in
compliance rates are future measures and far outside the scope of this action.
*p.218 - Emerging Issues, Bullet 1: Recommend deleting this as an emerging issue, moving it to Strategy C5.3, and editing it to say, “Evaluate approaches and mechanisms (e.g., a regional flush tax or
sewer surcharge) ) to establish a regional funding source to support local OSS programs.” I deleted SRF as an example because I don’t understand how SRF could be used to fund local OSS programs.
Such programs need dedicated revenues, not loans. SRF is a potential funding source for capitalizing a regional loan program (C5.3 NTA1) which is a related but separate action. The accompanying
measure for this new NTA should say, “evaluation completed or not” and should not go so far as to say, “regional funding source created or not.”
p.218 - Emerging Issues, bullet 3: Edit sentence 3 to say, “It can be difficult . . . to fund conversions, utilities . . . do not have the resources to subsidize these efforts.”
p.218 - Other ideas, last bullet: Edit to say, Develop standards of practice for OSS O&M service providers in the Puget Sound region.
p.224 - Strategy C6.1, Ongoing Programs: Edit sentence 1 to say, “. . . are not conveyed to wastewater treatment plants in amounts in excess of the plants’ treatment capacity or acceptance
requirements.”
p.225 - Strategy C6.2, Ongoing Programs: At the end of paragraph 2, clarify if you mean Snohomish County of the City of Snohomish.
p.226 - Strategy C6.3, Ongoing Programs: Consider spelling out SSO again in this section to help the reader.
p.226 - Strategy C6.3, Ongoing Programs, Bullet 1: Suggest spelling out MRA given that people may read C6 as stand-alone section.
C6: Wastewater Pollution
C6.1 NTA 1: We recommend deleting this NTA. For pollutants to be properly controlled through
permits, it requires both knowledge of what level of that pollutant represents a threat to what we
are trying to protect (criteria) and what level exists (monitoring results). We have neither
Washington State (chapter 173-201A WAC) nor “EPA recommended” aquatic life criteria for any
phthalates. And while EPA’s recommended human health criteria apply to five of the six phthalates
listed below, of the five standards, no POTW has ever been even close to these criteria for anything
but Bis-2-ethylhexyl phthalate. All pretreatment POTWs (and all other POTWs over 1.0 MGD) are
already required to submit at least four samples of effluent sampling results for these six phthalates
and all other priority pollutants in their next NPDES permit application. Targeting pretreatment for
more phthalate monitoring would imply that phthalates are commonly discharged by industrial
activities which such POTWs might control. However, all evidence to date points to the largest
source of phthalates being from consumer products, and thus no basis exists for targeting
pretreatment POTWs for such monitoring.
• National Recommended Water Quality Criteria:
http://water.epa.gov/scitech/swguidance/standards/current/index.cfm.
• Aquatic life criteria – None for any phthalates
• Human health for the consumption of water and organisms, organisms only
o bis 2-ethylhexyl phthalate, 1.2 ug/l, 2.2 ug/l
o butyl benzyl phthalate, 1500 ug/l, 1900 ug/l
o di-n-butyl phthalate, 2000 ug/l, 4500 ug/l
o di-n-octyl phthalate,
o diethyl phthalate, 17000 ug/l, 44000 ug/l
o dimethyl phthalate. 270000 ug/l , 1100000 ug/l (.11%)

C7.1 NTAs 1 and 2 are less important and less feasible than other NTAs; likely more appropriate for
future Action Agenda updates when more deliberation has occurred. If PSP is looking to reduce the
number of NTAs, these could be deleted. If NTA 2 is kept, it should be reworded to evaluate whether
it is appropriate (or is likely appropriate).
Page 209. Wastewater. The introductory text for this strategy does not include mention of industrial
discharges.
Page 214. Manage small onsite systems (C5.1). Onsite septic systems have not been mapped in Puget
Sound, nor has an inventory been prepared that shows the age of the systems. In order to better
understand the pollution issue and manage the pollution, this step is needed (similar to watershed
characterization).
Page 221. Centralized wastewater systems (C6). The number of facilities quoted is incorrect. There
are 104 municipal sewage treatment facilities in the Puget Sound basin that discharge to surface
waters. There are about 15 more that discharge to ground. There are a significant additional number
of industrial facilities.
Page 221. Industrial facilities (C6). It is confusing and inappropriate that industrial wastewater
facilities have been included in this strategy. They represent a significant load of pollution to Puget
Sound and given that a number of other items (“mitigation that works,” “working waterfronts,” etc.)
have been called out as specific strategies, it is surprising that a topic of this significance to Puget
Sound is not similarly standing alone. In addition, the types of actions appropriate for industrial
facilities differ in some key ways from those for municipal facilities.
Page 224. Reducing sources to sewage treatment plants (C6.1). As we have noted in previous
comments, the federal pretreatment requirements are inadequate. These need to be updated and
the state could do this for Puget Sound. Please include this as part of the action.
Page 225. Combined sewer overflow (CSO) systems (C6.2). CSOs are a major problem in specific
locations and this should be noted in the text. CSOs have contributed and continue to contribute
C.5 Chart (page 213) - Repair/Replacement/Fix OSS is not specifically identified as an intermediate
result. This would seem to fit into the "OSS Infrastructure" box, or possibly the "OSS O&M" box.

C.5 - The 2020 pressure reduction target isn't clear as to whether the first component
(inventory/fix/95% inspections metric) is determined based on the current MRAs, or based on the
larger MRA/Sensitive Areas (required by the second component).
C5.1, Ongoing Programs (page 215) - The sentence before "Near-Term Actions" should be corrected
to state that all OSS will be inventoried and 95% will have current inspections. It currently states that
95% will be inventoried.

C5.3 (On-site Sewage Systems - Emerging Issues and Future Opportunities (page 217) - The first bullet
(regional funding mechanism) does not represent a future opportunity. The lack of a program
funding source is described as the single biggest obstacle to achieving these targets and should be
addressed. This is essential and should be assigned more urgency, especially given that
"implementing and funding effective state and local on-site sewage programs" is stated as an
overarching strategy on page 212.

It is unclear what is meant by "fix all failures." An estimate of the scope of work to fix all failed
systems and a comparison to available funding should be addressed. The target for Ecology-funded
OSSS repairs/replacements is 78 systems/year. There are no specific goals for the other funding
sources for repair/replacement. It is unclear whether existing efforts are sufficient or if greater
efforts need to be made. There is an estimated 500,000 on-site septic systems in Puget Sound. The
Page 235. Establish No Discharge Zone for Commercial and Recreational Vessels (C8.1):
Add NTA 3: Ecology will work with the Port of Seattle and the Northwest & Canada Cruise
Association to support the proposed amendment introduced by Friends of the Earth, People for
Puget Sound and Puget Soundkeeper Alliance to the Cruise Ship MOU banning all cruise ship
wastewater discharges in MOU waters.

Performance Measure: Whether the Cruise MOU is amended by March 2012 and the number of
ships that petition Ecology to allow for continuous discharges of wastewater even while at dock.


I don’t see any reference to priorities for the various action items. What comes first??

I see no point in going after residential shoreline property owners considering any negative impact
they might have on the quality of the Puget Sound environment. Relatively speaking, the West Point
sewage plant and other large sewage plants need to be “fixed” before anything else is done to
restore the Sound. Also, I fail to see why City’s are exempt from rainwater runoff regulation.

Government should be first to clean up its act as government is the largest polluter.
• In the Section entitled “Reducing Pressures on the Puget Sound Ecosystem from Wastewater” (pg.
209), the discussion focuses only on enterococcus targets rather than both fecal coliform (FC) and
enterococcus. Note that FC is embodied in the marine water quality standards for primary
recreation (e.g. wading, boating), while enterococcus is used for secondary recreation (e.g.,
swimming, scuba). Recreational standards for freshwater are based on the FC targets alone.
Omission of FC is inappropriate unless the Action Agenda is only interested in focusing on secondary
contact.
• The strategy to “improve and expand funding options for small on-site sewage systems (OSS) and
local OSS programs,” (C5.3, pg. 217), could mention the potential efficiency gains from creation of a
centralized loan program rather than the current system of State Revolving Fund (SRF) loans to
individual counties, who then have to administer their own programs. This could make the effort to
repair OSS more consistent and uniform, and not subject to whether an individual county was
successful at securing an SRF loan.
• In the discussion of centralized wastewater systems (pg. 221), the statement in the last paragraph
under C6 should be changed slightly, as follows: “reducing the amount of impervious surface also will
may reduce the frequency and extent of CSOs and inflow and infiltration”, as this is not always true.
Also on the bottom of page 221, the discussion of targets should clarify that centralized treatment
plants are not likely the only or primary source of enterococcus on Puget Sound beaches.
Pages 224-225, C6.2 Reduce pollution loading to Puget Sound by preventing and reducing Combined
Sewer Overflows.

Something needs to be acknowledged here regarding pollutant loading from combined storm sewer
systems. In many cases, cities with combined systems and CSO events probably have less pollutant
loading to surface waters than those with separate systems. The reason is that much of the
stormwater that enters a combined system actually receives secondary treatment prior to discharge
to well designed and sited deepwater outfalls, while in a separated system, much of the stormwater
flows to surface nearshore water with less treatment and less initial dilution.


Sub- Task C5.1 - Effectively manage and control pollution from small on-site sewage systems
We request that PSP include the following specific action from the WSI into the Near Term Actions
under CS.l:
• Help local health jurisdictions carry out onsite sewage system management plans that inventory,
inspect, and fix failing onsite sewage systems in Marine Recovery Areas and other areas sensitive to
pathogen pollution.

C8.1 NTA 2
State Parks NTA 4: Ecology and DOH, with National Estuary Program grant funding, will coordinate
with Washington State Parks’ Clean Vessel Program to assist in construction, repair and monitoring
of pump-out stations to meet requirements of the NDZ petition (Appendix D, p. 491).

Comment: State Parks staff has not had the opportunity to discuss the scope of this item with Puget
Sound Partnership staff. Please note that we would like to include this item for discussion at our
February 10, 2012 scheduled meeting.


additional activities that are easily tracked for Parks and may be addressed by existing NTAs are:

•Septic/Sewer Upgrades – in the old action agenda this was also addressed as NTA C.3N2.3
C5: Industrial wastewater is not mentioned in the introduction of this set of strategies and should be.
(p. 209)
C5.1: It does not appear that there is an accurate inventory of the number of on-site sewage systems
within the Puget Sound. Compiling information, investigating existing OSS, and finding unknown on-
site sewer systems are a necessary first step to moving forward with managing and inspecting OSS.
Initiating such an inventory should be included in this strategy and near-term actions. (p. 215)
C5.1, NTA1: This assessment should include whether the self-reporting system now in place in
Whatcom County, and likely other counties, is adequate and reflective of actual conditions. (p 215)
As well, we find that redefining OSS failure as related to its cumulative effect should be undertaken
sooner rather than later. (Emerging Issues section, p 218)
C5.2 NTA: Why isn’t it a goal to permit all of the unpermitted LOSS? Perhaps 62 should be permitted
by April 2012, but the remaining 39 systems should be permitted soon afterward, by a given
deadline. (p 217)
C6: Industrial facilities are mentioned in brief in the introduction to this strategy; however it seems
that a topic of this significance should have its own section. Industrial facilities contribute large
amounts of pollution into the Puget Sound through wastewater and require actions that may not be
appropriate for municipal WWTP. We recommend that Industrial Facilities have their own section
and set of strategies within the Action Agenda. (p. 221)
C6.1: Pretreatment standards for industrial dischargers to municipal WWTP should be more stringent
and require a greater reduction of industrial toxics that are not easily removed in municipal WWTP.
Priority pollutant removal should be included for the treatment of all industrial wastewater. (p. 224)
C6.1, NTA: Monitoring industrial discharges for phthalates is not a sufficient goal for this strategy. In
addition to monitoring for phthalates, limitations on phthalates in industrial discharge should be
required within a given timeline. In addition, monitoring and regulations of persistent
page 209 - Local Strategies insert
Suggestion: Add the Strait to this list. A number of the Strait's additional 19 Strategic Priorities would
fit well under this Local Strategies highlight, namely, "Carlsborg Wastewater and Water Reuse
Strategy", "Sewage Discharges (Treated and Untreated)", and "Clean Water District Plans"

 In Section C5.3 you reference the ongoing work of Enterprise Cascadia (which is now Craft3; this
should be updated). However, you should add a specific near-term action to identify and provide
adequate funding to endow this public-private effort with adequate funds to sustain its efforts over
the long-term.
Local Action Agenda in Whatcom County and WRIA 1 (page 412) Further work is required to
complete this section of the PSP Action Agenda. From the link provided in the report, it seems that
local actions have been proposed. It is disconcerting that the Action Agenda Strategies tab refers to
similar sounding strategies whose numerical references are different from the current draft AA.
Linkages to Recovery Targets need to be identified. Ownership and accountability over this Local
Action Agenda is confusing. The organizational chart suggests the Whatcom Local Integrating
Organization (LIO) team would report through the WRIA 1 Management Team to WRIA 1 Policy
Boards yet the text describes the WRIA 1 Policy Boards to be the LIO.
• A notable accomplishment in this sub-basin is the reconnection of Lummi and Nooksack river
floodplains and tidal marshes through the Smuggler’s Slough project and significant restoration
opportunities remain in the broader Nooksack delta which should be integrated with the Action
Agenda floodplain strategy and the Marine and Nearshore restoration strategy.
• The Cherry Point Aquatic Reserve should be mentioned in a conservation context for this sub-basin
as should significant nearshore upland reserves.
• All threats identified seem to be salmon-centric and do not acknowledge significant losses to
nearshore habitat from the BNSF rail line or overharvest of marine species and the need to create
marine reserves for the recovery of rockfish species. We recommend that this list be expanded.
• Significant potential exists to restore nearshore functions and public access through the Port of
Bellingham waterfront redevelopment project and that should be called out as a priority opportunity
relevant to this planning horizon with specific nearshore objectives for the redevelopment plan
identified by the LIO as soon as possible.
• We are concerned that there is only one passing mention to the presence of the State’s two
largest refineries and a smelter along the Cherry Point reach or that its unique geomorphology
allows1/Whatcom LIO (page 415) - The explanationThis has led to Key Pressures table on site a 415 is
WRIA for deep draft ships to come close to shore. following the increasing pressure to page major
confusing in a number of aspects. First it references “ the table below”, which presumably refers to
the crosswalk table that the reader is directed to find on-line (website link URL provided at the
bottom of the page). However the URL link isn’t provided until another section. The link to the
crosswalk table should be provided immediately following the sentence about how the pressures are
organized by the PSP categories and explanations. Secondly, the explanation in the next sentence on
page 415 underneath the printed table states that “...the ‘key’ pressures are not inclusive of all the
pressures in the watersheds. The intent of the table is to identify the pressures most directly
associated with the ‘key threats and pressures” in the watersheds”. Presumably the ‘key” pressures
are referring to those listed in the table above this text; (or below?). The text should be revised so
that the statement about the ‘key pressures’ table (that is visible on the printed page) is immediately
before that table. The sentence that states, “The intent of the table is to identify the pressures most
directly associated with the ‘keythere is only one passingin the watersheds” should probablyrefineries
Page 412. It is remarkable that threats and pressures” mention of the State’s two largest be
and a smelter located along the Cherry Point reach or that its unique geomorphology allows for deep
draft ships to come close to shore. This has led to increasing pressure to site a major coal terminal in
this region that is likely to have major construction and operational impacts on marine life. The
Action Plan should more broadly address the number of ocean-going vessels that are serving these
facilities both from the perspective of the number of ships and the volume of petroleum moving
through our marine waters.
The Action Agenda in Whatcom County and WRIA 1
In general, the action agenda for Whatcom County and WRIA 1 is incomplete. The key threats and pressures identified for Whatcom County and WRIA 1 are entirely
focused on freshwater and upland ecosystems, resulting in marine and nearshore environments being completely ignored. While salmon recovery and freshwater
ecosystems are of incredible importance, the nearshore and estuarine systems are as well.
To begin, the table of key threats and pressures (p 415) fails to acknowledge the effect of commercial and residential development and runoff on nearshore and estuarine
ecosystems. The table also does not recognize the impact of agricultural runoff on nearshore and estuarine ecosystems in WRIA 1. We request that this table be
revisited to portray a more accurate representation of pressures on Whatcom County and WRIA 1 ecosystems.
We also request that the impacts of overwater structures and shoreline armoring be evaluated for inclusion as key threats and pressures for this region. The Nearshore
and Marine Protection and Restoration strategies (B1-4) focus on the need to regulate and manage the construction of overwater structures and shoreline armoring. The
lack of discussion of these aspects of nearshore protection highlights inconsistencies between the Puget Sound Action Agenda and the local strategies and applications.
Overwater structures increase shading in the nearshore habitat and can be detrimental to eelgrass beds, essential elements of these habitats. In addition, overwater
structures can act as vectors for contaminants into the nearshore ecosystem. Acknowledging overwater structures as a key threat in this region is also incredibly
important given the extent of residential, commercial, and industrial development along marine shorelines. As such, overwater structures should be identified as a key
threat to the health of Whatcom County nearshore and estuarine ecosystems.
Shoreline armoring is identified as a key pressure to WRIA 1 freshwater systems, but it is also a threat in nearshore and estuarine areas. Disconnecting nearshore and
terrestrial landscapes through shoreline armoring can have very detrimental effects on the health and resilience of nearshore ecosystems. We request that shoreline
armoring and its effects on nearshore and estuarine ecosystems are included within the table of key pressures and threats in WRIA 1.
Vessel traffic, ballast water, and the potential for oil spills are, in addition, major threats and pressures to the Whatcom and WRIA 1 nearshore environment. Vessel
traffic and ballast water contribute to noise, environmental contamination, and the introduction of invasive species. In addition, this kind of vessel traffic and the nature
of the industry along shorelines of Whatcom County, including oil refineries and aluminum smelting, increase this risk of oils spills and introduction of contaminants into
the nearshore and marine environments of Whatcom County. Pollution from point discharges and smokestacks should also be considered a threat to the health of the
fresh and marine waters of Whatcom County.
Bacterial pollution and risks to shellfish beds must also be included in the table of threats to WRIA 1 ecosystems. Commercial and recreational shellfish beds are an
important part of Whatcom County’s economy and cultural identity. Great effort has been given to protect the shellfish beds of Drayton Harbor, Birch Bay and Portage
Bay. This effort has included increased monitoring of fecal coliform pollution in freshwater and marine waters, including Terrell Creek, Birch Bay, Drayton Harbor, and the
Nooksack River. A TMDL for the Nooksack River has been developed, and local government and organizations have worked on public education and outreach efforts
about decreasing bacterial introductions to waterways. In addition to threatening the health of shellfish beds, bacterial contamination can make Whatcom County’s
beaches unsafe for recreational activities.
Finally, climate change should be identified as a key threat to Whatcom County ecosystems. Strategies should be developed to address local adaptations to projected
changes associated with climate change, such as sea-level rise and changes in precipitation patterns.
- The Preliminary Working Draft for Whatcom County Area
The Preliminary Working Draft for Whatcom County Area attached to this section (p 415), is often vague and neglects many areas of importance within the Whatcom
B4.1 Use, coordinate, expand and promote financial incentives and programs for best practices at
ports and in the marine industry that are protective of ecosystem health…Key Ongoing Program
Activities: Ecology, in conjunction with the Clean Boatyard Washington program, will work toward
ensuring Puget Sound boatyards meet the requirements as described in the Boatyard General Permit
with a goal that 100% of Puget Sound boatyards covered under the Boatyard General Permit will

and marinas covered under the NPDES Industrial Stormwater permit will comply with the permit’s
benchmarks and SWPPP requirements.” Note that “benchmarks for copper and zinc in stormwater
discharges” are, according to best available science, too high to protect ecosystem health.
Response



Eelgrass was added as requested




Edits were made as requested



The funding strategy and discussions of prioritization address funding needs emphasize that all ongoing programs for
Puget Sound should be fully funded; funding actions for ongoing programs were added only when the owning agency
asserted that the program could not accomplish its mission to protect/recover Puget Sound because of lack of funding
(there are few of these). Further decisions about recommendations on funding will be made after the evaluation of
ongoing programs later in 2012.
Ag runoff NTAs were changed significantly and the final NTAs are a product of negotions between Ecology, Agriculture,
and the Conservation Commission.




The actions discuss the process the three agencies are using to determine an approach to ensuring best managmeent
practices meet water quality standards and any recommendations about changes to regulations will be a product of
those discussions.
Many of the editorial changes were made; challenge text was also edited significatly by Ecology and WSDA. The Ag
runoff NTAs are a product of negotiation between Ecology, WSDA and the conservation commission and clarify the
NRCS issue.




This NTA was added as requested




This NTA wasadded to the shellfish section (See C7.1 NTA 3).




The Partnership appreciates this suggestion but it was not added it to the Action Agenda at this time. It could be
reconsidered in the future if there was support from the agricultural community.
The final NTAs for agricultural runoff are a result of negotiations between Ecology, WSDA and the Conservation
Commission; Agency comments were incorporated into the final NTAs.




New NTAs added; the agricultural runoff NTAs went through significant revisions and negotiation between WSDA,
Ecology, and the Conservation Commission, and the exact language was modified during those conversations.
The list of acronyms and references was updated.




Appendix C was updated to include British Columbia as part of the West Coast Governors Agreement, transboundary
indicator was added. Other examples are included, but the appendix was not intended to be an exhaustive list of all
collaborative efforts and opportunities.




The Management Conference diagram is being updated to include NWSC. The internal sections of the diagram were
drawn to show only those entities that PSP had direct operational connections with (created, funded, directed, staffed)
and/or were linked by statute. With PSP's 2012 funding of the NWSC, it is appropriate to include the Commission in the
implementers section of the diagram with LIOs.
Strait ERN provided final NTAs and profile text which was used throughout the Action Agenda.
Changes made. The total number of listed species are not reflected in this chapter. It only addresses those listed
freshwater and terrestria speciesl - state listed marine species are discussed in the preceeding chapter.




Duplicate language deleted



Changes made
Changes made - this section adds the sea bird forage fish threshold idea, cross references related recovery plans for
marine species in other sections of the Action Agenda. NTA 10.1.1. remains unchanged.




Changes made




Added federal HCPs and a brief discussion of local programs that support protection and conservation of biodiversity.



comments noted; changes made to extent possible




Changes made
C11.5 NTA 1 was dropped and this topic is addressed in D4 (monitoring).




Discussion of plastics (first bullet in Emerging Issues and Future Opportunities) was amended to refer to the Strait ERN
designation of strategic priorities & actions.
Changes made as suggested.
The introduction to C9 was revised to describe the number of TMDLs needed.

No change related to toxics TMDLs -- toxic-related impairments are addressed by the contaminated site clean up sub-
strategy.

The key ongoing program activities for the site cleanup sub-strategy includes a note about the importance of post-
construction monitoring. Also, the discussion of continual assessment of information about contaminated sites was
moved so it is included among key ongoing program activities rather than future and emerging issues; this type of
assessment is the process by which the need for cleanup would be evaluated for issues such those mentioned for the
Nooksack River & Cherry Point.

The discussion of emerging and future issue for dredged materials management was revised to include a statement
about the interest in additional analysis of dioxins in disposed material.

We were not able to develop a broadly accepted near-term action for plastics and microplastics. The discussion of this
action was amended based on other comments but this issue appears only as a future opportunity.




C11.5 NTA 1 is dropped and this topic is addressed in D4 (monitoring).
The introduction to TMDLs recognizes the backlog; the inclusion of the TMDL process in the Action Agenda is an
attempt to work through this backlog. Also, strategy C7 introduces an initiative to advance pathogen contamination
controls in the Nooksack.

A future and emerging issue was added to assess mechanisms to ensure that goals of non-point source TMDLs are met.

Analysis of interim clean ups and discussion of improving public participation in clean ups was added to the section on
emerging/future issues.




List of areas affected by chronic hypoxia was amended to remove reference to increasing problems in Whidbey Basin
and Quartermaster Harbor. Creosote piling removal is addressed in B2.2 NTA 4.




Evaluation of contaminated areas is included as an ongoing program and language was clarified that this is work that
Ecology does continually as part of its toxics cleanup program.

Discussion of funding for TMDL implementation and PIC programs was added as an emerging/future issue; PIC programs
also are addressed in C7.1 NTA 3.
Text changed as suggested




The key ongoing program activities for the site cleanup sub-strategy includes a note about the importance of post-
construction monitoring. Also, the discussion of continual assessment of information about contaminated sites was
moved so it is included among key ongoing program activities rather than future and emerging issues; this type of
assessment is the process by which the need for cleanup would be evaluated for issues such those mentioned for the
Nooksack River & Cherry Point.




Discussion of "challenges" has been broadened to include a description of the Puget Sound freshwater TMDLs which
includes a number of impairments related to dissolved oxygen, fecal coliform bacteria, temperature, and toxic
chemicals.

Discussion of clean ups was clarified with edits provided by Ecology will be edited as suggested.

Suggested NTA for incentives/binding mechanisms to ensure implementation of nonpoint pollutant reductions specified
in TMDLs was considered, but this NTA was not added based on input from Ecology. This concept was added to the
emerging and future issues section.


Text was changed as suggested in these comments and per comments from others. To respond to others' comments,
the discussion of continual evaluation of contaminated sites was shifted from emerging and future issues to the ongoing
programs for site clean up.
Retained a single section C11.3 but added text about freshwater beach programs using the language provided in this
comment.

Revised C11.3 NTAs as suggested.

Revised C11.4 and C11.5 text as suggested.




The final 2012 Action Agenda incorporates climate change more significantly than the December 2011 draft. Preparing
for Climate Change: Washington State's Integrated Climate Response Strategy (April 2012) is integrated throughout the
strategy sections. The Action Agenda strategies and actions help implement the recommendations called for in the state
strategy. Where possible, climate change is incorporated into the 2012 Near-term actions. As identified in the Action
Agenda, most of the strategies, sub-strategies and near-term actions are "no regrets" or "win win" actions that reduce
existing stresses in the ecoystem. In addition, integration needs are identified in the future considerations section.
Climate change adaptation is a criterion in the sub-strategy ranking process. The Action Agenda also includes discussion
of long-term considerations related to climate change including selection of indicators and targets beyond 2020. The
Partnership is not taking additional public comment on the final 2012 Action Agenda so that the region can focus on
implementation. However, climate change adaptation is a long-term endeavor and future updates will include
opportunity for both public input and comment.
The final 2012 Action Agenda incorporates climate change more significantly than the December 2011 draft. Preparing
for Climate Change: Washington State's Integrated Climate Response Strategy (April 2012) is integrated throughout the
strategy sections. The Action Agenda strategies and actions help implement the recommendations called for in the state
strategy. Where possible, climate change is incorporated into the 2012 Near-term actions. In addition, integration
needs are identified in the future considerations section. Climate change adaptation is a criterion in the sub-strategy
ranking process. The Action Agenda also includes discussion of long-term considerations related to climate change
including selection of indicators and targets beyond 2020. Puget Sound related climate impacts are summarized. The
University of Washington Climate Impacts Group, in collaboration with the Puget Sound Partnership and Puget Sound
Institute, is updating the synthesis of climate science in Puget Sound to reflect the most-to-date impacts across Puget
Sound and as geographically specific as possible.




The Partnership welcomes opportunities to collaborate with Canada on sea level rise and other issues. Sections B1-3 of
the Action Agenda were significantly revised to incorporate sea level rise issues. Opportunities to cooperate with
Canada are included in the Management Conference Appendix.


The final 2012 Action Agenda incorporates climate change more significantly than the December 2011 draft. Preparing
for Climate Change: Washington State's Integrated Climate Response Strategy (April 2012) is integrated throughout the
strategy sections. The Action Agenda strategies and actions help implement the recommendations called for in the state
strategy. Where possible, climate change is incorporated into the 2012 Near-term actions. In addition, integration
needs are identified in the future considerations section. Climate change adaptation is a criterion in the sub-strategy
ranking process. The Action Agenda also includes discussion of long-term considerations related to climate change
including selection of indicators and targets beyond 2020. Puget Sound related climate impacts are summarized. The
University of Washington Climate Impacts Group, in collaboration with the Puget Sound Partnership and Puget Sound
Institute, is updating the synthesis of climate science in Puget Sound to reflect the most-to-date impacts across Puget
Sound and as geographically specific as possible. The Partnership agrees that more people and organizations need to
be involved in refining specific strategies from a climate adaptation perspective. Habitat connectivity needs are
identified as needing additional work in the future.
The final 2012 Action Agenda incorporates climate change more significantly than the December 2011 draft. Preparing
for Climate Change: Washington State's Integrated Climate Response Strategy (April 2012) is integrated throughout the
strategy sections. The Action Agenda strategies and actions help implement the recommendations called for in the state
strategy. Where possible, climate change is incorporated into the 2012 Near-term actions. In addition, integration
needs are identified in the future considerations section. Climate change adaptation is a criterion in the sub-strategy
ranking process. The Action Agenda also includes discussion of long-term considerations related to climate change
including selection of indicators and targets beyond 2020. Puget Sound related climate impacts are summarized. The
University of Washington Climate Impacts Group, in collaboration with the Puget Sound Partnership and Puget Sound
Institute, is updating the synthesis of climate science in Puget Sound to reflect the most-to-date impacts across Puget
Sound and as geographically specific as possible. The climate introductory section was revised and now includes the
concept of "no regrets" and "win win" actions as part of the adaptation strategy, as well as the longer time horizons for
projected impacts. The Action Agenda does not include the more technical diagrams and graphics suggested. These
would appropriate for the new work underway with the UW Climate Impacts Group. Once that summary update is
completed, more accessible graphics can be created. In the future, the Miradi can be modified to show climate change.
The Partnership received comments on the diagrams that that they both overally complex, and need to show the
important actions, difficulty of actions, and other information. For the 2013 update to the Action Agenda, the diagrams
will be more comprehensively updated.




The sea level rise data included is was review University of Washington Climate Impacts Group. The Partnership agrees
that impacts could be non-linear. The UW Climate Impacts Group is in the process of updating the synthesis of climate
impacts in Puget Sound. The data shown the 2012 Action Agenda is likely to be adjusted based on their updated work.
In the wastewater section of the Action Agenda, the potential need for relocation is identified, as well as the need to
consider sea level rise for retrofit projects.
The Action Agenda includes discussion that existing policies, plans and tools may not include climate change impacts,
and may not be adequate in the future. Treaty right obligations would be broadly covered by this issue. Additional work
to identify and address policy and programmatic changes that might be needed related to climate change will continue
to be needed in the future.
The final 2012 Action Agenda incorporates climate change more significantly than the December 2011 draft. Preparing
for Climate Change: Washington State's Integrated Climate Response Strategy (April 2012) is integrated into the
recovery context, the introduction to Section 3 and each strategy sections. While a climate change focused strategic
initiative was not selected as a cross-cutting strategic initiative, each initiative does include information on how climate
change adaptation is advanced.




The Partnership agrees that the Northwest Straits Initiative could take a leadership role in providing outreach on ocean
acidification in northern Puget Sound. The Governor's Blue Ribbon Panel on Ocean Acidification has convened to
provide recommendations by October 2012. Completion of the Blue Ribbon Panel work is a near-term action, and
implementation of those recommendations is identified as an emerging opportunity. Once those recommendations are
in place, the next steps for Puget Sound should be clearer.

The climate change section is about to the long-term trends of global warming. The Action Agenda includes discussion
that the Pacific Northwest has a highly variable climate, and climate adaptation work will occur in this context.




The introductory material about climate change and adaptation was reworded in the final draft. The intent is for the
Action Agenda. The introductory section on climate response strategies was revised to incorporate acknowledgement
that local governments and others are working on climate change. Throughout the Action Agenda, the state response
strategies are incorporated as a way to be consistent throughout the document. The local profiles incorporate some
locally-based climate adaptation information, and more can be added in the future. Strategy conveners were subject
matter experts some of whom are public agency staff. The use of the terms projections and predications came directly
from the UW Climate Impacts Group.
The 2012 Action Agenda includes calls for the protection of farms and forests, as well as limiting development in
floodplains and floodplain reconnection as part of climate adaptation strategies.




The final 2012 Action Agenda incorporates climate change more significantly than the December 2011 draft. Preparing
for Climate Change: Washington State's Integrated Climate Response Strategy (April 2012) is integrated throughout the
strategy sections. The Action Agenda strategies and actions help implement the recommendations called for in the state
strategy. Where possible, climate change is incorporated into the 2012 Near-term actions. In addition, integration
needs are identified in the future considerations section. Climate change adaptation is a criterion in the sub-strategy
ranking process. The Action Agenda also includes discussion of long-term considerations related to climate change
including selection of indicators and targets beyond 2020. Puget Sound related climate impacts are summarized.




The final 2012 Action Agenda incorporates climate change more significantly than the December 2011 draft. Preparing
for Climate Change: Washington State's Integrated Climate Response Strategy (April 2012) is integrated throughout the
strategy sections. The Action Agenda strategies and actions help implement the recommendations called for in the state
strategy. Where possible, climate change is incorporated into the 2012 Near-term actions. In addition, integration
needs are identified in the future considerations section. Climate change adaptation is a criterion in the sub-strategy
ranking process. The Action Agenda also includes discussion of long-term considerations related to climate change
including selection of indicators and targets beyond 2020. Puget Sound related climate impacts are summarized.
For #9: The prioritization framework was amended to include climate change as a criterion. The Action Agenda includes
sub-strategies related to full implementation of environmental laws and regulations, and permitting for the Gateway
Project is a responsiblity of federal, state and local governments. For #10 #11, #14, #15, #16, #17, #20, #21, #22, #25,
#26, and #34: The final 2012 Action Agenda incorporates climate change more significantly than the December 2011
draft. Preparing for Climate Change: Washington State's Integrated Climate Response Strategy (April 2012) is integrated
throughout the strategy sections. The Action Agenda strategies and actions help implement the recommendations
called for in the state strategy. Where possible, climate change is incorporated into the 2012 Near-term actions. In
addition, integration needs are identified in the future considerations section. Climate change adaptation is a criterion
in the sub-strategy ranking process. The Action Agenda also includes discussion of long-term considerations related to
climate change including selection of indicators and targets beyond 2020. Puget Sound related climate impacts are
summarized. For #12: The Action Agenda includes soundwide and local strategies and actions that are "no regrets" and
"win win" for reducing existing stresses and addressing climate change impacts. Partnership agrees that local
implementation of climate related strategies is needed. To the extent that information is available and local areas
discussed climate change, this information is included in the local profiles (e.g., see Hood Canal profile). The Partnership
is working with the UW Climate Impacts Group and Puget Sound Institute to update the summary of climate impacts in
Puget Sound, including geographic specific information. For #23: Protection of natural areas is incorporated into the
Action Agenda. New energy initiatives will continue to need to be evaluated as they are put forward.




Text on this issue was added to the introductory language. In consultation with DNR, the eelgrass strategy as moved to
a sub-strategy in the marine/nearshore section (See B2.4).



The Partnership appreciates this review and affirms that continuing work to ensure actions will result in achievement of
targets and to develop interim milestones to track progress towards targets will be ongoing after the Action Agenda is
adopted. Nutrient inputs addressed largely in wastewater (OSS) and ag runoff, see C3 and C5. Continuation of the pilot
programs on use of bivalves as filter feeders is addressed in shellfish (see C7.3 NTA 4). continuation of pilot programs to
explore this use), no change on filter feeder issue made.


The eelgrass section was move to a sub-strategy of marine/nearshore in consultation with DNR (see B2.4).



This example is very helpful; interim milestones will be developed for all targets after the Action Agenda is published
and this example can serve as a starting point for those discussions about the eelgrass target.
The requested NTA was added back and cross-references to wastewater were added. The Partnership agrees that
interim milestones to track progress towards targets are needed; these will be developed after the Action Agenda is
adopted. In consultation with DNR the eelgrass strategy was moved to a sub-strategy of the marine/nearshore section
(See B2.4).




DNR provided information on the native/non-native issue which was added to the introductory text. Reference to
including BC in workshops/consultation was added.




DNR provided information on the native/non-native issue and it was added to the introductory text.




In consultation with DNR the eelgrass strategy was moved to a sub-strategy of the marine/nearshore section (See B2.4).
Climate change impacts and adaptation are discussed at the beginning of that Section. Reference to the NW Straits
work was added to B2.4.




The Partnership discussed these comments with DNR and did not add ‘eelgrass bed connectivity and shoot density’ to
description of DNR’s ongoing work because the current DNR protocol does not yet consider these parameters. DNR
agrees that parameters like this would be valuable future additions to the monitoring effort. Text on boating was
added. DNR provided language on the native/non-native issue and it was added to the introduction to the eelgrass
strategy (now B2.4). The regulatory process associated with the NPDES permit will address herbicide effects on native
eelgrass.
The langauge of the executive summary has been edited significantly to address concerns about termonology and to
clarify the relationship to the BSWP.




We received many comments expressing the need for a short document highlighting the key work of the Action Agenda;
the highlights document was developed to meet this need and the introductory text was edited. Legislative actions
have been expanded (where needed) and incorporated into the general NTA list, so they are no longer a stand-alone
list. Concerns about fully capturing ongoing programs will be addressed in the future as part of the program evaluation
work that will be undertaken after the Action Agenda is published.




The executive summary; in addition, as the strategic initiatives and prioritization effort is complete, a "highlight"
document will be developed, this document will emphasise the co-managemetn efforts between the Federal and tribal
governments.
The Partnership appreciates this support for work to address environmental contaminants. We will continue to work to
strengthen the way the Action Agenda addresses how environmental contaminants affest fish and wildlife resources in
future Action Agenda updates.




The executive summary has been edited significantly and the informaiton on local actions has been improved.
Development of strategic initiatives and prioritization are ongoing processess to address the concern about
development of a short focused list.




Support for floodplain protection noted. The Partnership agrees that working landowners should be involved in
developing and implementing solutions.




The Partnership agrees that economic viability in the Puget Sound region is critical to protection and restoration of
Puget Sound and that affordable housing is an integral part to maintaining this viability. This will be one of the issues
that the Puget Sound Floodplain Protection and Recovery Team considers.
The Partnership appreciates the support for many of the floodplain actions and has made edits to A5.1 NTA 1 and A5.1
NTA 3. We also agree with the need for full vetting of actions with partners and opportunities for public comment. The
Partnership welcomes participation by the City of Burlington and Dike District 12, and appreciates the support for the
formation of an LIO. While pre-draft materials were available for early review, an LIO structure would, in the future,
allow partners more and earlier access to materials as they are developed.




At this time the Partnership is not willing to delay any consideration of floodplain management and FEMA program until
resolution of all legal actions. Many partners do not support delay. Care will be taken to consider these actions moving
forward and, if needed, approaches will be adjusted consistent with their outcomes.
All of the final near-term actions that include the Department of Commerce were carefully negotiated with the Agency
and agency comments were incorporated. A5.4 NTA 2 was edited (new number is A5.3 NTA 2); A5.5 NTA 2 (now A5.4
NTA 3) refers to the floodplain identification work that will be carried out by the Puget Sound Floodplain Protection and
Policy Team, which will be more specific to floodplains than the broader Puget Sound Watershed Characterization work;
A5.4 NTA 2 was deleted and moved to the future opportunities section.
The Partnership has made the following changes to address these comments: The floodplain definition is will be
developed as part of A5.1 NTA 1. The term "flood risk reduction projects" was clarified, reference to NRCS programs
were added to ongoing programs, changes to the discussion of FFFP were made. A5.4 NTA 1 on highways and
floodplain functions was narrowed, in discussion with WSDOT, to focus on state highway facilities. Other roads and
railroads could be considered in the future. This section of the Action Agenda includes both protection and restoration.
In some watersheds, restoration is necessary.




The following changes were made. The term flood control was replaced. With respect to protection and restoration of
floodplain habitat, the Partnership agrees that both are necessary. Protection of land at imminent conversation is
addressed specifically in A2.1 NTA 4 and protection of intact floodplains in A5.3. We will carefully consider the
workgroup membership suggestions when convening the Puget Sound Floodplain Protection and Policy Team.
Reference to the Ruckelshaus Process was removed; A5.1 NTA 2 was deleted; A5.1 NTA 3 was clarified and added to the
work of the Puget Sound Floodplain Protection and Policy Team (addressed in A5.1 NTA 1). Any Partnership role in the
local municipal adoption of seven actions to comply with ESA would need further discussion and could be addressed as
part of the work under A5.1 NTA 1. A5.4 NTA 1 (now A5.3 NTA 1) was clarified and expanded. A5.4 NTA 2 (now A5.3
NTA 2) was retained, the Partnership will ensure that Ecology and Commerce (who are leading this NTA) ware aware of
the concerns about potential conflicts between state and federal regulations. Strategy A1.3 calls for (among other
things) enforcement of laws, plans, regulations and permits consistent with ecosystem recovery, we have not reiterated
that specifically in the floodplain section, but we agree that appropriate enforcement is needed. A5.3 calls for
protection of intact floodplains (which would prevent further subdivision); we have not incorporated a specific strategy
on removal of fish passage barriers, we have added NTAs on implementation of the Puget Sound Salmon Recovery Plan.
Finally, we have expanded discussion of climate change adaptation in all of the strategies and have removed the specific
climate sub-strategy (proposed A5.6) from floodplains.

[The role of PSP is to achieve the adopted 2020 floodplains recovery target, which assumes full compliance with the
BiOp. To the extent that PSP has a role to play in facilitating municipal compliance, efforts are limited to measuring how
compliance with the BiOp is contributing, or not, to achieving the target and educating communities and municipalities
of the potential flood hazards as well as ecosystem services that floodplain function offers. ]
The following edits were made. 5.6 NTA 1 was dropped as adding a member of the Science Panel does not meet the
definition of an NTA. Partnership staff communicated this desired to the Science Panel chair and Science Director. We
agree that appropriate consideration of climate change is important to successful implementation of many near term
actions. A discussion of climate change and how the floodplain sub-strategies and actions related to Washington
State's climate plan was added to this section. The Puget Sound Floodplain Protection and Policy Team to be convened
under A5.1 NTA 1 will address the definition of floodplain. A5.5 NTA 2 (now A5.4 NTA 3) was carefully reviewed by the
Conservation Commission and the final language, which incorporates references to local watershed groups, and the
final performance measure is realistic in their view. A5.6 NTA 2 was deleted.




All comments noted. Care will be taken to consider these actions moving forward and, if needed, approaches will be
adjusted consistent with their outcomes. No change to A5.1 NTA1, as this was vetted by floodplains IDT. However, the
Partnership owns this action and the implementation related comments here can be used when that work is underway.
No change on A5.1 NTA 4, as this is very difficult to measure. However, the proposed measure could be discussed future
with FEMA. Changes made to draft on comment related to ongoing programs in A5.2




A4.1 NTA 3 was combined with other draft floodplain NTAs and made part of the charge for a (to be convened) Puget
Sound Floodplain Protection and Policy Team; this Team will have broad representation to ensure full participation in
vetting all these important issues for Puget Sound. The Partnership agrees that ensuring plans provide appropriately for
buildable land is part of protecting and recovering Puget Sound in a way that also supports a vibrant economy.
The Partnership appreciates the support for many of the floodplain actions. The Floodplain Team will address levee
setbacks, among other issues. The Partnership notes that A5.2 (on aligning programs) is a sub-strategy meant to
encourage ongoing efforts at alignment, including efforts to develop new regional levee-based vegetation standards, no
new near-term actions focused specifically on alignment are proposed. The NTA on public perception of flood risks was
dropped and moved to the future considerations sections for future development if warranted.




The references to the WWRP have been deleted from the discussion of ongoing programs in the floodplain section. The
Partnership is sensitive to the need to coordinate reporting requirements with state agencies that already have project
data and reporting and will continue to work closely with RCO on this issue.
The Partnership appreciates the support for many of the floodplain strategies and the observation that they will provide
useful data and information for local governments. Due to the ongoing nature of the BiOP, care will be taken to
consider these actions moving forward and, if needed, approaches will be adjusted consistent with their outcomes. The
Partnership strongly agrees that local governments will need to be involved in A5.1 NTA 1. A5.3 NTA 1 (now A5.4 NTA 1)
has been revised and narrowed, in consultation with WSDOT to focus on state highway facilities.




The Partnership appreciates the support for the floodplain strategies and actions.



The Partnership agrees about the need to consider floodplains both in the context of developing areas, rural areas, and
already developed areas,aand this was recently reinforced by the ECB. We acknowledge that moving infrastructure out
of heavily developed floodplains is unlikely. We agree with the need to coordinate the efforts of the (to be convened)
Puget Sound Floodplain Protection and Policy Team with local efforts including local project prioritization and decision-
making frameworks. A5.1 NTA 2 was deleted. A5.3 related to floodplain restoration projects was not retitled, the NTAs
in this sub-strategy include transportation projects (which was coordinated with WSDOT), and agricultural land projects
(which was coordinated with the Conservation Commission and WSDA). In future Action Agenda updates, other actions
may be added. The Partnership thinks it is important to have a sub-strategy specifically focused on implementing and
maintaining floodplain restoration projects and to populate that sub-strategy with the most appropriate near-term
actions in any give Action Agenda update. The sub-strategy on protecting and maintain intact and functional
floodplains includes an action to evaluation how BiOp compliance will contribute to the Puget Sound recovery
floodplain target.
The Partnership appreciates this support for the floodplain strategies and the (to be convened) Puget Sound Floodplain
Protection and Policy team; we agree, in particular, that local knowledge will be critical in consideration of how best to
address floodplains, and we agree with the importance of involving the US Army Corps in the Team.




The updated Strait profile included a statement about the priority and an updated local action. These changes are
reflected in this section.




The Partnership appreciates this support for the floodplain strategies and would welcome the participation of the Upper
Skagit Tribe in future floodplain discussions.
The Partnership understands this concern of local governments. Care will be taken to consider these actions moving
forward and, if needed, approaches will be adjusted consistent with their outcomes. We will discuss those changes with
WASC and others.




The Partnership appreciates this support for the floodplain strategies. We agree that the expertise of flood
management experts in local and tribal governments and in the federal agencies will be important and we will be
working to involve them in the Puget Sound Floodplain Protection and Recovery Team. Language on the levee
vegetation issue has been strengthened and made more specific. These detailed comments will be helpful with the
Floodplain Team is convened.
The Partnership appreciates the Conservation Commission's support for the floodplain strategies and participation in
development of floodplain actions. The language of the final floodplain actions that are owned by the Conservation
Commission was carefully negotiated with the Agency and Agency comments were incorporated. A5.5 NTA 3 was
moved to the ongoing program section.




The Forest Runoff draft and comments were provided to DNR and Ecology for review; both DNR and Ecology provided
extensive revisions, all of which were incorporated.
The Forest Runoff draft and comments were provided to DNR and Ecology for review; both DNR and Ecology provided
extensive revisions, all of which were incorporated.


The Partnership consulted with DNR and Ecology on these comments. The introductory text and ongoing program
descriptions in forest runoff address these issues; we agree that further funding for roads is needed, the importance of
this issue also is discussed in the Funding Strategy.




Reference to WDFW has been removed from the NTA on the Elwha River weir. This NTA was provided by the Straits
ERN. NTAs on steelhead population identiy and viability criteria and the steelhead recovery plan have been added to
the Salmon recovery strategy (now A6). the steelhead NTAs were negotiated with WDFW. An NTA on prairie and oak
woodlands has been added to the strategy on upland and terrestrial restoration (now A2).




Strategies and actions on freshwater restoration have been consolidated with some of the other land strategies and
now appear as A2.2. A cross reference to strategies and actions on freshwater flows (now A7) has been addded. The
langauge introducing the freshwater restoration strategie has been edited to include referece to the restoration work
occuring in urban areas.
The Partnership appreciates these edits and has made the corrections. A secion on climate changes has been added to
the discussion of salmon recovery and to the discussion of upland and terrestrial protection and restoration.




The Partnership agrees that climate change must be addressed when planning restoration projects. A section on
climate change has been added to the land strategies and will be identified as a future opportunity in the final Section
A2. The language introducing the freshwater restoration strategies has been edited to include reference to the
restoration work occuring in urban areas.




The Partnership agrees that upland and terrestrial protection and restoration are important. We have worked to
strengthen this section in response to comments and see it as an opportunity for further improvement in future action
agenda updates. We agree that better integration of the federal ongoing programs and any near-term actions is
needed. In April 2012, the Partnership received a large spreadsheet of federal actions developed in response to the
treaty rights at risk paper. There was not sufficient time to review and incorporate these actions, but they can be
incorporated in the the future. The Partnership appreciates the support for the A6 (now A2 actions). Many programs
and actions in the Action Agenda are not well funded at this time (see the funding strategy).




The Partnership appreciates this comment and has worked with other parnters to improve the discussion of terrestrial
restoration including adding an NTA on pararie and oak woodland restoration.
The match requirement will be listed as a future opportunity in the final funding section.




This NTA has been moved to the salmon strategy (now A6). The final wording was provided by the Strait ERN.




A reference to the elk enhancement projects was added to the description of ongoing programs.




The Partnership discussed this suggestion with the Conservation Commission; final NTAs on stewardship programs in
this Action Agenda are focused on programs related to agricultural and forest lands. Additional NTAs on stewardship are
in A5.




The role of the Action Agenda is to identify the work needed to recover Puget Sound as defined by six legislatively
established goals. The Action Agenda is based on the assumption that the on-going work of federal, state, local, tribal
and other entities around the Sound must continue as an important part of the recovery effort. The Partnership will be
evaluating on-going programs later this year. The Action Agenda also recognizes that the current efforts are not moving
us towards recovery at a fast enough rate to meet our 2020 recovery goals. Near term actions are the additional work
that is necessary to achieve the 2020 recovery goals. As new work, many of those actions are not funded.

The ECB has convened a committee to address funding needs for implementation of the Action Agenda. They have
decided to focus on the highest priorities as represented by the strategic initiatives. The first step in their process will
be to conduct a funding gap analysis for each initiative. Discussion of new funding will be based on a clear
understanding of need as represented by the priorities in the strategic initiatives.
The intent of the funding strategy and identified actions with steps is to address the very shortfalls identified in the
comment letter. Economic incentives and disincentives are not directly mentioned in 2012 actions. However, as the
funding approaches and strategies are further developed and vetted by the Ecosystem Recovery Board, DNRs
suggestions can be incorporated. The modifer "even" was not deleted. It reflects input received during development of
the Action Agenda. The words "proposed budget cuts" were not deleted. This phase was included so that if and when
agencies need to show budget cuts, the Partnership can help identify what important priorities will be unfunded.




The three funding actions were added as NTAs in Section C5. They are also reshown in the Funding Strategy.




This idea was not included in the Funding Section at this time. Assessing impacts on a parcel by parcel basis throughout
Puget Sound was identified as a priority action. The Partnership staff cannot find such a reference in Appendix E.
The Partnership appreciates King County's support and leadership to help create a specific funding strategy as described
in the comment. A summary of the work plan of the new Ecosystem Coordination Board Funding Subcommittee was
added to this section. This work includes an evaluation of existing expenditures, an assessment of financial need, and
proposals on how to fill identified gaps. The Action Agenda does not include the quantitative information about
estimated costs and current focus and investments. As the ongoing program evaluation work is completed and the
work of the ECB subcommittee advances, a more complete cost estimate can be developed. The range of unfunded
costs for the Chinook Recovery Plan and stormwater retrofits are included in the Action Agenda. As the work of the ECB
Funding Subcommittee advances, the strategic initiatives are more fully developed, and the funding actions outlined in
the Action Agenda are underway, additional conversation will be needed about funding issues such as allocation and
roles within the Partnership.




The Partnership recognizes that all areas of Puget Sound face budget shortfalls, and that local governments are
struggling to implement their responsibilities. Allocation between areas of Puget Sound is identified as a need for future
consideration.
Comment noted. The Partnership agrees that all the funding actions presented need to be implemented, and
appreciates the support of the Point No Point Treaty Council.




Partnership agrees that a comprehensive and integrated federal, state, and local funding strategy linked to priority
actions is needed. A summary of the ECB work plan to help develop this strategy was added to this section. It would
include, as suggested, identify the costs for Action Agenda implementation, identify funding gaps and develop
proposals to fill the gaps. For FS1.1: The USACOE was added to the list of federal agencies. The term "other partners"
includes local governments, although local governments are not specifically mentioned. For FS1.3: Comment noted.
Commenter agrees with the proposed actions. Partnership agrees that existing mandates need to be included in any
grant prioritization process as described. For FS 1.4: Comment noted. The Partnership agrees that an integrated
strategy is needed and that local governments cannot bear costs on their own. This concept is recognized in the
funding strategy. FS1.5: Further development of private sector partnerships is identified as a future opportunity.
The Partnership agrees that a robust, integrated funding strategy is needed. The recently formed ECB sub-committee
will be helping the Partnership to develop this strategy. A summary of the subcommittee work plan was added to this
section. This work includes an evaluation of existing expenditures, an assessment of financial need, and proposals on
how to fill identified gaps. The Action Agenda does not include the quantitative information about estimated costs and
current focus and investments. As the ongoing program evaluation work is completed and the work of the ECB
subcommittee advances, a more complete cost estimate can be developed. The suggestions from the caucus will
considered during that process in 2012. Once the top priorities in the Strategic Initiatives are clarified, the work to
identify the funding gaps and opportunities can be more fully identified. The Partnership appreciates the Caucus
support and participation in the ECB subcommittee.




The intent of the funding strategy is diversify and stablize implementation funding, as well as improve the efficiency and
effectiveness in the use of current funds. A variety of sources will be needed, some of which are new. The NTA for the
Department of Defense was revised with the Partnership as the owner. the local government tax increase has been
widely discussed by local governments and the Ecosystem Coordination Board. Protection of working lands is part of the
overall strategy for long-term protection and recovery of Puget Sound in Section A. This includes development of
agriculture strategy for the Puget Sound region. Rapid aquisition of properties in agricultural production is not called for
in the Action Agenda.




Comment noted. The Partnership acknowledges and appreciates the support of WRIA 8 for the funding strategy and
local funding mechanism. The Partnership recognizes that other ILF programs exist. The ones called out in the Action
Agenda have specific dates for implementation.
The Partnership apprecriates WRIA 9's leadership in helping build the funding strategy. The NTA for legislative action
for local government funding was revised based on comments. Local legislative actions were not identified through the
LIOs, but could be in the future. The requested information about the EPA grants and outcomes was not included in the
final Action Agenda. This is important information and could be considered as part of the ECB analysis in further
developing the funding strategy.




Projects on private land are often identified in the three-year work plans for the salmon recovery watersheds (see
Substrategy A6.1 and related actions). Several near-term actions include incentives for private landowners. For example,
A3.1 NTA 2 (TDRs and ecosystem services), A3.1 NTA 3 (forest watershed services), A5.4 NTA 2 (ag land ecosystem
services markets), B1.3 SJI 7 (technical assistance), B2.1 NTA 2 (community use docks), B2.3 NTA 1 (homeowner
incentives for landward setbacks), C3.1 NTA 2 (effectiveness of incentive programs), C3.1 NTA 3 (Voluntary Stewardship
Program), C4.2 NTA 2 (Accelerate Family Forest Fish Passage Program Implementation, C5.3 NTA 1 (low interest loans
for onsite site systems).

The Partnership agrees that a narrow set of priorities is needed, and looks forward to working with local governments
to create them. We have made significant efforts to simplify the Action Agenda, including creating the strategic
initiatives, reducing the number of strategies and substrategies by combining related ideas, and reducing the number of
near-term actions and working with action owners to clarify action content and expected outcomes. We will continue
to work with all partners to populate the strategic initiatives.

The Partnership agrees that local governments are on the front lines of protection and recovery in Puget Sound and
understands the constraints and concerns of local governments. Support for local government implementation is better
identified in the Action Agenda. Continued local government participation on the ECB funding subcommittee will is
important in identifying determine sources and amounts being spent on strategic initiatives compared to the
anticipated amount needed. We will continue to work with local governments on the concern that the recovery targets
appear regulatory. Additional text has been added to the introduction to clarify the role of the targets.

The Partnership recognizes that some partners were not sure how their comments were addressed as the Action
Agenda was being developed. The Partnership received much unanticipated written and verbal comment before the
comment period, but in effort to keep the work on track did not produce interim comment summaries. We apologize if
comments were missed in that process. For A1.3, the word "willingness" was removed, and the sub-strategy now reads:
"Support local governments to adopt and implement plans, regulations and policies consistent with protection and
recovery targets, and incorporate climate change forecasts". For A1.1 NTA:, the participation of local governments is
now explicitly called out in the NTA: "...Development will occur in coordination with Commerce, DEW, DNR and local
government representatives."
Process and target setting: The Partnership acknowledges that AWB continues to have concern about the target setting
process and the land cover target in particular. Text has been added to the introduction of the Action Agenda that the
targets are not regulatory. The Leadership Council will revisit the targets as needed and we look forward to working
with AWB when that occurs. The Partnership disagrees that setting targets is outside the path set by the legislature.
The targets are intended to tell us where we are going and what success looks like. Without targets, an evaluation of
ongoing programs is would not be as useful. The Partnership will conduct the evaluation of the ongoing programs after
the Action Agenda is adopted. We acknowledge that AWB would have liked this to occur before the Action Agenda.




The Partnership has created the three strategic initiatives as a way to narrow the priorities. The Partnership agrees that
we should be able to look across our investments in Puget Sound protection and recover to ensure that money is being
wisely spent. The ongoing program evaluation will be completed after the Action Agenda is adopted. The Action
Agenda adoption was delayed beyond April so that partners have more time to review the work completed to date and
reach agreement on the priority actions. In addition, the Ecosystem Coordination Board new funding sub-committee
has business representation and will help develop an overall funding strategy for implementation.
The Partnership appreciates your support - please refer to responses on your specific comments on the floodplains
section.




The Partnership agrees that local governments are on the front lines of protection and recovery in Puget Sound and
understands the constraints and concerns of local governments. Support for local government implementation is better
identified in the Action Agenda. Continued local government participation on the ECB funding subcommittee will is
important in identifying determine sources and amounts being spent on strategic initiatives compared to the
anticipated amount needed.
Ecosystem recovery at the scale of Puget Sound is complex. We appreciate Dews comment that Action Agenda cannot
be adopted without major new analysis and revision, but respectfully disagree. The Partnership has made significant
improvements since 2008 including setting recovery targets, showing the alignment of actions to targets and goals. We
know that a risk analysis for Puget Sound would greatly strengthen the Action Agenda, but that work has not yet been
completed and has not always been recognized as the highest priority work by the Leadership Council and others. The
Strategic Initiative concept will help address some of Dews concerns and we appreciate Dews leadership in completing
the Action Agenda and populating the strategic initiatives. A near-term action has been added to develop the interim
milestones to help guide the work out to 2020. In addition, the Partnership has worked with DFW and others to identify
steps of individual actions beyond 12-18 months, but that work remains uneven as agencies have been hesitant to
commit to work that is not funded. Should we add text explaining the relationship of goals, targets , pressures, ongoing
programs, ntas? We have made significant efforts to simplify the Action Agenda and make it easier to navigate. These
include: Developing the strategic initiative concept as a clear articulation of the most important priorities for action in
2012/2013, reducing the number of strategies and substrategies by combining related ideas, reducing the number of
near-term actions and working with action owners to clarify action content and expected outcomes, moving the
majority of the Open Standards for Conservation Result and Logic Chain diagrams to an appendix, moving the local
strategy information into tables (as opposed to text boxes) throughout, and working to edit and simplify language
throughout. Should we add something about where we will be when the NTAs are complete? The progress comments
about what we have learned and what is going well and where the region is falling short will be addressed in the State
of the Sound report. This clarification has been added to the Action Agenda. The local area call out boxes were replaced.
Restoration is a important part of recovery and this is reflected in the habitat strategic initiative and some actions. The
Partnership agrees that preventing problems in the first place is important, and in some locations, restoration is the
most important work. This idea has been reinforced by recent ECB discussions. The Partnership recognizes that the
ongoing program work as presented is uneven. We have relied on Action Agenda participants for this information.
While improvements were made between the draft and final, we agree that a more systematic listing can be developed
in future updates. The definition of NTA was clarified so that it can be better linked to ongoing program work. The
Partnership is continuing to work with DFW and other agencies to improve staff coordination and requests and
understand DFW staff constraints.
Ecosystem recovery at the scale of Puget Sound is complex. The Partnership tries to balance the need to show the full
detailed picture of recovery and communicate the highest priorities in a concise way. We have made significant efforts
to simplify the Action Agenda and make it easier to navigate. These include: Developing the strategic initiative concept
as a clear articulation of the most important priorities for action in 2012/2013, reducing the number of strategies and
substrategies by combining related ideas, reducing the number of near-term actions and working with action owners to
clarify action content and expected outcomes, moving the majority of the Open Standards for Conservation Result and
Logic Chain diagrams to an appendix, moving the local strategy information into tables (as opposed to text boxes)
throughout, and working to edit and simplify language throughout. An executive summary has been added. At DNR's
request, a Partnership NTA was added to develop the interim milestones. We agree that identifying specific barriers and
addressing them is important. As DNR is aware, the tribes have identified barriers and the response process has been
both moving in parallel to and slightly out of sync with the Action Agenda. With the delay in adoption, these processes
might be better in sync. The Strategic Initiative will, in part, respond to DNRs comments. We agree that the Action
Agenda should not be seen as a playbook. We appreciate DNRs leadership in completing the Action Agenda and
populating the strategic initiatives.




The Vital Signs Table was edited to match the Vital Signs website. The list of legislative actions was deleted from the
introduction and legislative actions are included in the sections and NTA table. The Partnership chose to consolidate the
public education, outreach and behavior change strategies in Sections D5-7. In the future those could be more
distributed throughout sections of the Action Agenda.
Puget Sound Starts Here is a behavior change campaign. It is not the same as the Action Agenda. The Action Agenda is
not focused solely on salmon, shellfish and orca. The Action Agenda specifically addresses human caused issues ranging
from our land use and shoreline development patterns and practices, to how we administer regulatory programs, our
use of chemicals, and how we address wastewater. These are the stressors on salmon, orca, and people. The
Partnership encourages and supports citizen action through the EcoNet groups, as well as local project prioritization in
individual watersheds and areas. For example, see Section A6.1 for the implementation of the salmon recovery three
year work plans, and the local profiles. Partnership staff would be happy to connect the commenter to local groups in
his area.




We have made significant efforts to simplify the Action Agenda and make it easier to navigate. These include:
Developing the strategic initiative concept as a clear articulation of the most important priorities for action in
2012/2013, reducing the number of strategies and substrategies by combining related ideas, reducing the number of
near-term actions and working with action owners to clarify action content and expected outcomes, moving the
majority of the Open Standards for Conservation Result and Logic Chain diagrams to an appendix, moving the local
strategy information into tables (as opposed to text boxes) throughout, and working to edit and simplify language
throughout. An executive summary has been added. An NTA has been added for the Partnership to set the interim
milestones. The definition of a near-term action was clarified. We can continue to work with Ecology and other action
"owners" to make sure that this definition is evenly understood and applied. The NTA list has been revised and will be
further clarified before the Action Agenda is adopted in summer 2012. We appreciate Ecology's support to include
ongoing programs and concur that the evaluation of the ongoing work occur after the Action Agenda is adopted. We
appreciate Ecology's leadership in completing the Action Agenda and populating the strategic initiatives. The shellfish
section (now C7) was significantly revised in discussion with Ecology and others to reflect the WSI.
This comment is partially addressed in Section B1.1. As Marine Spatially Planning is still a developing tool, these ideas
will be captured in the future opportunities section for Section B1-3.




The Partnership made significant efforts to better define strategies and sub-strategies and to use the terms in the
appropriate context throughout the Action Agenda.

The Partnership agrees that we should be able to look across our investments in Puget Sound protection and recover to
ensure that money is being wisely spent. Under the Legislation that established the Partnership we are required to
evaluate ongoing programs and make recommendations. (See RCW 90.71.370.) The statute provides us a list of
programs to evaluate and questions to ask about each program. That work will be completed after the Action Agenda is
adopted.

The Partnership is happy to discuss compatible baseline mapping with Canada if that is identified as a priority. This idea
will be listed in the Management Conference Appendix for the final Action Agenda.
The Partnership has always planned for a responsive summary after the official public comment period. We received
substantial input during the process in the form of written comment and chose to produce one comment summary. We
acknowledge that this choice was frustrating for some partners. Monitoring and education comment: The Partnership
chose to consolidate the monitoring and education comments in Section D as much as possible. We agree with that
putting these important elements in one place or consistently in each strategy is this right approach. Improvements
were made between the draft and final, and this structure can be revisited in the future. Increase compliance with laws
comment: The substrategies were revised to more consistently reflect this need. Delegated federal responsibilities
comment: The Partnership agrees that the federal programs and delegated responsibilities could be clarified. A more
comprehensive picture of the federal work in Puget Sound is needed and will have occur in the future. The Partnership
received federal program information related to the Treaty Rights at Risk paper in April and was not able to incorporate
it for the planned April adoption. Climate change comment: Climate change information is now included for all
strategies and sub-strategies. Near-term action comment: For NTA ideas in the draft or received during the comment
period that did not make it into the final Action Agenda for a variety of reasons are included in each relevant strategy
section under future considerations. Prioritization comment: With a delay of the Action Agenda adoption until summer
2012, there will be a opportunity to look critically at the final NTAs as part of the strategic initiative population process.
Executive summary comment: A new standalone Executive Summary will be part of the final Action Agenda. Salmon
centric approach comment: Many partners believe that salmon recovery is central to Puget Sound recovery. Significant
regional planning and implementation work has been achieved for salmon recovery and it is called out specifically.
Other species are included in the Action Agenda in a less prominent way. Pressure definition comment: The definition
was modified. Indicator and status comment: Additional context as suggested will be incorporated before the Action
Agenda is adopted. How do we recover PS comments: The introductory sentence was revised. Open Standards is not
defined, but a link is provided. The legislative actions are no longer separately identified. Fish passage is not separately
called out in A2.2 or A6.1, however the projects in A6.1 do contain fish passage projects. Ongoing program comment:
We agree that a more consistent presentation of ongoing programs is needed. However, as this work is not complete,
that task can be better accomplished in the future. The LIO comment: LIO background is presented on page 299 and
NTAs and ongoing programs comment. The Partnership agrees that ultimately having a way to integrate priorities of
ongoing programs and near-term actions is important. Ongoing program work will be evaluated once the Action Agenda
is complete. NTA comments: The NTAs have been refined since the draft. All have owners and measures. Actions that
did not advance (no owner, outcome was vague) were moved to future opportunities. The measures will continue to
need improvement. Some action owners are reluctant to commit without funding in place. References were improved
and the Partnership is grateful for the help of EPA staff on the local profile references. Prioritization will be completed in
summer 2012, including integration of the local actions. Should we retitle Section C? I'm ok to do this. The Partnership
agrees that local funding process needs to be further developed. The recently formed ECB sub-committee can include
this need in their scope. The outreach and funding sentences were deleted. The Partnership knows and the Action
Agenda states that the LIO work will continue to be developed, and has developed in different ways in different areas.
The adoption resolution will contain wording about LIO additions as their work is more solidified. We have worked to
simplify the language throughout the Action Agenda and reduce the number of terms. For the final Action Agenda, the
LIO text will be clarified in the introduction of Section 3, the LIO introduction and in the Management Conference
Appendix. The required formal coordination mechanism was added to the Management Conference Appendix. The
Biennial Science Work plan actions are not included in the Action Agenda as requested by EPA. The Science Panel,
however, supports the legislative intent to keep the development of the Action Agenda Update and Priority Science
separate but complementary. The first is a stakeholder-based process; the latter is intended to be a scientific analysis
that may use stakeholder information to inform priorities. Likewise, although the enabling the legislation calls for a
biennial science work plan, it is also requires that the plan recommend strategic improvements to the ongoing science
work in the Puget Sound (see Appendix A of Priority Science). Consequently, Action Agenda Update strategies inform
scientific priorities but Priority Science is not simply a biennial science work plan that lists science needed to implement
near-term actions in the Action Agenda Update. Action C1.1 NTA 6 was added to help address the comment about
emerging contaminants. The Partnership agrees that coordinated implement Ted strategies at the Puget Sound and
local scales would be helpful. Some of the soundwide NTAs have local elements (e.g., SMP update related NTAs). We
The Partnership has undertaken significant outreach with its partners to further refine strategies, sub-strategies, and
actions since the draft. The changes you proposed in the toxics section have all been made.




The Partnership will complete the evaluation of ongoing programs once the Action Agenda is complete. We agree that
showing the delegated federal authorizes would be helpful and this can be accomplished in a future update cycle. The
climate change integration was significantly strengthened between the draft and final Action Agenda. The hope is that
the Action Agenda structure is stable to be used in the future with more minimal update processes.




Thank you. The Partnership agrees that we should be able to look across our investments in Puget Sound protection
and recover to ensure that money is being wisely spent. Evaluation of ongoing programs will be completed after the
Action Agenda is adopted.




Comment noted. Restoration is a major focus of several sub-strategies and actions in the Action Agenda.
This NTA was added to the Agricultural runoff section (C3.1 NTA 3).




Comments noted. The Partnership respectfully disagrees that the need to protect and recover Puget Sound is a
manufactured crisis. This is a bi-partisan, multi-partner process of diverse interests working to identify priority actions
to protect Puget Sound's resources now and for the future.



Text edits made.




Comments noted. The Action Agenda does not blame or focus on individual sectors or geographic areas, and includes
actions to both protect and restore ecosystems throughout Puget Sound.
We have made significant efforts to simplify the Action Agenda and make it easier to navigate. These include:
Developing the strategic initiative concept as a clear articulation of the most important priorities for action in
2012/2013, reducing the number of strategies and substrategies by combining related ideas, reducing the number of
near-term actions and working with action owners to clarify action content and expected outcomes, moving the
majority of the Open Standards for Conservation Result and Logic Chain diagrams to an appendix, moving the local
strategy information into tables (as opposed to text boxes) throughout, and working to edit and simplify language
throughout. An executive summary has been added. The Strategic Initiative should help address the NTA comment. The
Partnership received more ideas for NTAs during the review process and has worked to include the ones that met the
definition. Local action is more fully included in the final action agenda. Many local areas identified actions for
themselves and the suggested action for the salmon recovery plans is included as sub-strategy A6.1 with numerous
actions. Alignment of programs with the recovery targets will require careful consideration. For example, other
commenters have concern about the Partnership overstepping the geographic confines of Puget Sound and getting into
statewide laws and programs. If King County can help identify specific locations in the Action Agenda to include this
idea under future considerations, this can be added for the final Action Agenda in summer 2012. We agree that a less
frequent update cycle is desirable. The Action Agenda framework should be stable moving forward so the update
process can be simplier. An NTA was added for the Partnership to set interim milestones, and all NTAs have
performance measures. Some of the measures will need improvement over time. We agree that identification of
barriers is important. The tribal white paper and responses have some of this information. That process has been
moving in parallel and may be able to be incorporated in summer 2012. There are several Soundwide NTAs that help
foster local implementation (e.g., A1.1 NTA 1, A1.2 NTA 2, B1.2 NTA 1). The statement that the Action Agenda requires
broad implementation is covered in the introduction.

We have made significant efforts to simplify the Action Agenda and make it easier to navigate in response to comments.
These include:
• Developing the strategic initiative concept as a clear articulation of the most important priorities for action in
2012/2013.
• Reducing the number of strategies and substrategies by combining related ideas.
• Reducing the number of near-term actions and working with action owners to clarify action content and expected
outcomes.
• Moving the majority of the Open Standards for Conservation Result and Logic Chain diagrams to an appendix.
• Moving the local strategy information into tables (as opposed to text boxes) throughout.
• Working to edit and simplify language throughout.




We have worked to include language clairfying that the work to protect and recover Puget Sound as contemplated by
thestatue includes the Puget Sound watersheds as well as in the marine environment.
Partnership staff have worked to clarify term Partnership in the Action Agenda. "Agency" is added where appropriate.
The prioritization process incorporates the concerns raised about the actions. NTA wording has been clarified as much
as possible to focus on action rather than "convene" or "study". The Partnership agrees that action is paramount. In
some cases, convening or study is the right next step, however. We have tried to move those steps to the performance
measures rather than focus of the action. All actions have performance measures and some of those will need
improvement. The Action Agenda is not about pet projects. The Action Agenda is not based on a zero budget approach
as many of the ongoing programs that support recovery have other mandates and purposes (e.g., NPDES).




The federal response to the tribal Treaty Rights at Risk paper was being developed during the Action Agenda. At the
same time, the state response is not yet developed. With the delay in the Action Agenda adoption, better integration of
these efforts and the Action Agenda may occur in terms of identifying actions. The Partnership agrees that continued
investment in monitoring and research is important.




The Partnership will conduct the evaluation of the ongoing programs after the Action Agenda is adopted. We
acknowledge that Master Builders and AWB would have liked this to occur before the Action Agenda. Text has been
added to the introduction of the Action Agenda that the targets are not regulatory. The Partnership walks a balance of
needing to identify recovery work needed, not just deliver an Action Agenda based on funding available. We are,
however, sensitive to the concern that many actions needed are not funded. The actions in the Action Agenda are
negotiated and not all partners will agree with all actions as some believe actions go too far and other think the actions
do not go far enough. The Strategic Initiatives and newly formed ECB sub-committee will help narrow the work needed
in the next two years and a way to fund it.
The Partnership revised the presentation of the local strategies, so that they are featured more fully and more
prominently at the beginning of each strategy section in which a local priority has been identified. Some local areas
have more fully developed priorities than others. The Action Agenda does not just call out research and monitoring.
Local WRIA work and implementation of the three-year work plans is identified as sub-strategy A6.1 with numerous
related actions.
Ecosystem recovery at the scale of Puget Sound is complex. The Partnership tries to balance the need to show the full
detailed picture of recovery and communicate the highest priorities in a concise way. We have made significant efforts
to simplify the Action Agenda and make it easier to navigate. These include: Developing the strategic initiative concept
as a clear articulation of the most important priorities for action in 2012/2013, reducing the number of strategies and
substrategies by combining related ideas, reducing the number of near-term actions and working with action owners to
clarify action content and expected outcomes, moving the majority of the Open Standards for Conservation Result and
Logic Chain diagrams to an appendix, moving the local strategy information into tables (as opposed to text boxes)
throughout, and working to edit and simplify language throughout.

The ECB did not agree that prioritizating actions with multiple objectives, although this idea can continue to be
advanced as the strategic initiatives are finalized in summer 2012. The Initiatives should achieved the recommendation
for high level, cross cutting strategies. The importance of estuary restoration is better called out in the Action Agenda in
strategy B2. As a component of A5.1 NTA 1, the Partnership will, by December 2012, convene a Puget Sound Floodplain
Protection and Recovery Policy Team to establish a working definition of ‘floodplain’ and ‘floodplain function’ in the
context of the 2020 floodplains recovery target. The nearshore and marine protection and restoration sections were
reorganized and several specific NTAs were added. The salmon recovery section was strengthened with revised sub-
strategies and NTAs.




We have made significant efforts to simplify the Action Agenda and make it easier to navigate in response to comments.
These include:
• Developing the strategic initiative concept as a clear articulation of the most important priorities for action in
2012/2013.
• Reducing the number of strategies and substrategies by combining related ideas.
• Reducing the number of near-term actions and working with action owners to clarify action content and expected
outcomes. Many partners suggested new actions during the review.
• Moving the majority of the Open Standards for Conservation Result and Logic Chain diagrams to an appendix.
• Moving the local strategy information into tables (as opposed to text boxes) throughout.
• Working to edit and simplify language throughout.

The Partnership is aware of the concerns and constraints facing local governments.Numerous actions, and the funding
strategy, are designed to help local governments.
Since the draft, the Partnership worked closely with all entities that would be responsible for implementation of near
term actions to add specificity and clarify responsible parties.

The Partnership has included "habitat protection and restoration in support of salmon recovery" as a strategic initiative.
The salmon recovery section was also significantly revised between the draft and final and now includes salmon
recovery specific NTAs, including full funding of the Chinook Recovery Plan, implementation of the individual three year
workplans and lead entity capacity.




The Partnership acknowledges the concern that near-term actions not be proposed or advanced until cost-benefit work
is complete. The Partnership's responsibility is to identify the worked needed to protect and recovery Puget Sound. We
are in agreement that money needs to be wisely invested, and in some cases, actions needed are not part of ongoing
work or not funded adequately to acheive the desired outcomes. We appreciate the concern that the some actions
could be identified with repercussions beyond Puget Sound. Those types of actions would need careful consideration to
move forward as they may or may not benefit other areas of the state.




The ongoing work of the Northwest Straits Initiative has been added to numerous locations in the Action Agenda (e.g.
ongoing programs in Section B and D5-7) as suggested for specific sections. There are two near-term actions for the NW
Straits Foundation in Section B3.2 These were written in cooperation with NW Straits Foundation. The other ideas
suggested by NW Straits were not developed into near-terms due to the scale of the proposed action or general nature
of the idea. As much as possible, these ideas are captured in the emerging opportunities sections. Local area work is
developed locally and for those areas with approved LIOs, and West Sound, those groups approved their submitted
text. MRCs participate in those efforts.
The Partnership has been in close communication with the NWIFC and individual tribes, as well as EPA and NOAA on the
status of the federal response to the Treaty Rights at Risk Paper. The Action Agenda update and the federal response
have remained slightly out of sync. With the delay in the adoption of the Action Agenda until summer 2012, the
Partnership will continue work with the tribes and federal agencies to have the response reflected in the Action Agenda.
We agree with NWIFC that having the response with the Action Agenda is helpful for Puget Sound recovery.
Climate change: Implementation of the recommendations of the Ocean Acidification is called in future considerations.
The Partnership anticipates that the PCSGA would be part of those discussions. The shellfish section (now C7) was
signigicantly revised to ensure it corresponds with the Governor's shellfish initiative.




Comment noted. The final actions worked out with Parks are in the Action Agenda.
Ecosystem recovery at the scale of Puget Sound is complex. We have made significant efforts to simplify the Action
Agenda and make it easier to navigate in response to comments. These include:
• Developing the strategic initiative concept as a clear articulation of the most important priorities for action in
2012/2013.
• Reducing the number of strategies and substrategies by combining related ideas.
• Reducing the number of near-term actions and working with action owners to clarify action content and expected
outcomes. Many partners suggested new actions during the review.
• Moving the majority of the Open Standards for Conservation Result and Logic Chain diagrams to an appendix.
• Moving the local strategy information into tables (as opposed to text boxes) throughout.
• Working to edit and simplify language throughout.




The Partnership agrees that action is critically important, and that local governments are on the front lines of protection
and recovery in Puget Sound and their work must be represented. The 2012/2013 Action Agenda includes a funding
strategy that would help support local government and other’s efforts to implement priority actions for recovery.
Thank you. The Partnership has included "habitat protection and restoration in support of salmon recovery" as a
strategic initiative. The salmon recovery section was also significantly revised between the draft and final and now
includes salmon recovery specific NTAs, including full funding of the Chinook Recovery Plan, implementation of the
individual three year workplans and lead entity capacity.

The Partnership agrees that as cities and counties are asked to redouble their efforts to protect and restore Puget
Sound they must be given adequate support and resources to accomplish the job. The financial burden must be shared
by all levels of government. The 2012/2013 Action Agenda includes a funding strategy that has many actions designed
to secure higher levels of funding to support local government and other’s efforts to implement priority actions for
recovery. An ECB subcommittee is currently working on a gap analysis to determine sources and amounts being spent
on strategic initiatives compared to the anticipated amount needed. That will inform a proposal for specific funding
mechanisms later this year.

The Partnership provided continued support of local processes to identify, refine and prioritize local strategies and near-
term actions. At this time, seven out 10 local integrating organizations either have a short list of priorities to address, or
specific working list of priorities under consideration. Five out of 10 LIOs identified near-term actions that can be
tracked for implementation in this Action Agenda.

The Partnership agrees that we should be able to look across our investments in Puget Sound protection and recover to
ensure that money is being wisely spent. Under the Legislation that established the Partnership we are required to
evaluate ongoing programs and make recommendations. (See RCW 90.71.370.) The statute provides us a list of
programs to evaluate and questions to ask about each program. We will complete that evaluation by the end of 2012.
On-going program evaluation work will be informed by the sub-strategy ranking process.



Throughout the Action Agenda finalization process in the spring 2012 and summer 2012, the Partnership has been in
close communication with the tribes on the status of the federal response. The processes may still align for the final
adoption. The Partnership agrees that holding the recovery work in one place would be helpful.
The Partnership recognizes the work of the Puget Sound Conservation Districts, and has reflected their work throughout
the Action Agenda, including sections A2.2, A3.1, A5.4, A6.5, B1.3, C2.4, C3.1, C7.1, and the local profiles. Numerous
near-term actions for the Conservation Commission were worked out between the draft and final Action Agenda.




We have made significant efforts to simplify the Action Agenda and make it easier to navigate in response to comments.
These include:
• Developing the strategic initiative concept as a clear articulation of the most important priorities for action in
2012/2013.
• Reducing the number of strategies and substrategies by combining related ideas.
• Reducing the number of near-term actions and working with action owners to clarify action content and expected
outcomes.
• Moving the majority of the Open Standards for Conservation Result and Logic Chain diagrams to an appendix.
• Moving the local strategy information into tables (as opposed to text boxes) throughout.
• Working to edit and simplify language throughout.
• Updating technical terms and acronyms in the technical appendix
Citizen enforcement is covered by the revised sub-strategies, although not called as a near-term action. The Partnerhip
would be willing to include Soundkeeper Alliance in the ongoing programs and need guidance on the specific efforts to
include. Many programs called out the in Action Agenda need funding.




We have made significant efforts to simplify the Action Agenda and make it easier to navigate in response to comments.
These include:
• Developing the strategic initiative concept as a clear articulation of the most important priorities for action in
2012/2013.
• Reducing the number of strategies and substrategies by combining related ideas.
• Reducing the number of near-term actions and working with action owners to clarify action content and expected
outcomes.
• Moving the majority of the Open Standards for Conservation Result and Logic Chain diagrams to an appendix.
• Moving the local strategy information into tables (as opposed to text boxes) throughout.
• Working to edit and simplify language throughout.
Partnership staff will continue to work with RCO on data and reporting concerns.
The Action Agenda is meant to call out support for implementation of the existing programs such as NPDES and SMP. It
does not supersede these efforts. Where necessarily, ways to strengthen or improve those programs may be identified.
The revised sub-strategy language should clarify the concern raised by the commenter. The Partnership is aware that
local governments have taken substantial regulatory responsibility. The Action Agenda is not intended to imply that
local governments have not taken action, rather it is intended to support those efforts. The revised near-term actions
should address the concern. More regulation is not a focus of the Action Agenda.




Climate change: The Action Agenda incorporates climate change more significantly than the December 2011 draft.
Preparing for Climate Change: Washington State's Integrated Climate Response Strategy (April 2012) is now integrated
throughout the strategy sections.. Where possible, climate change is incorporated into the near-term actions. In
addition, integration needs are identified in the future considerations sections. Monitoring and research: A more robust
monitoring program description will be included in the final Action Agenda. Monitoring and education is primarily
covered in one section, although the Partnership agrees that these apply to all sections. This organization could be
revisited in future updates. Research primarily covered in the Biennial Science Work Plan. Enforcement and compliance:
Several sub-strategies were revised to better articulate the need for adequate and consistent enforcement and
compliance. Additional mandates related to enforcement are not part of the Action Agenda, and numerous partners do
not support that type of action. Transparency and LIOs: Most of the LIOs are relatively new. Opportunities to improve
transparency of those local processes exist. The Partnership hopes that those concerns can be worked out locally. If not,
Partnership staff can assist. We recommend contacting the staff person for your area if this is the case. Marine recovery
comments: Marine nearshore recovery is linked to salmon recovery. The priorities are developed locally and
implementation of the local salmon recovery workplans (Section A6.1) has actions for nearshore areas, as well as
uplands. Prioritization: The strategic initiatives will allow for the prioritization as described by the commenter. Rapid
response action comment: This action is included in the Action Agenda. The Partnership agrees that bold action is
needed now.
The Partnership agrees that conservation districts are important local partners. If there are specific concerns about
conservation districts or agriculture not being included in LIOs or LIO discussions, please let Partnership know so that we
can assist in remedying the situation. The Partnership appreciates support for the Strategic Initiative and the language
was changed to include a focus on shellfish bed recovery. The Partnership agrees that working through existing effective
structures such as the conservation districts is important for recovery.




Clarity comments: We have made significant efforts to simplify the Action Agenda and make it easier to navigate in
response to comments. These include: Developing the strategic initiative concept as a clear articulation of the most
important priorities for action in 2012/2013, reducing the number of strategies and substrategies by combining related
ideas, reducing the number of near-term actions and working with action owners to clarify action content and expected
outcomes. Ecosystem recovery at the scale of Puget Sound is complex and the Partnership recognizes the need to have
a comprehensive approach as well as a way to simply and clearly communicate a shorter set of priorities. The Strategic
Initiatives are designed to acheive what the commenter has suggested in terms of clarity in moving forward on a concise
set of actions. Legislative section comment: The legislation section as presented in the draft was deleted. The
Partnership agrees with the Seattle's comment that legislative actions are better presented in a comprehensive picture
of priority work needed. LIO related comments: The local work is better integrated into the final Action Agenda in the
strategies and sub-strategies and near-term actions. As described in the Action Agenda, the intent of the LIOs is to bring
together local priorities. The Action Agenda describes why the Whidbey Basin Action Area is too large for the type of
priority identifiication needed as well as the current steps to create and LIO in the Skagit. The text will be re-edited for
the final for consistent of terms like local area. The Partnership agrees that the ongoing program work is not complete
for local governments or federal agencies. This is work that can be improved over time. Some of the ongoing local work
is captured in the profiles. The 2008 data base work is somewhat useful, but it was also a never complete picture of the
work (information was very general, overly detailed, or missing).
Framework and simplification comment: We have made significant efforts to simplify the Action Agenda and make it
easier to navigate in response to comments. These include: Developing the strategic initiative concept as a clear
articulation of the most important priorities for action in 2012/2013, reducing the number of strategies and
substrategies by combining related ideas, reducing the number of near-term actions and working with action owners to
clarify action content and expected outcomes. Ecosystem recovery at the scale of Puget Sound is complex and the
Partnership recognizes the need to have a comprehensive approach as well as a way to simply and clearly communicate
a shorter set of priorities. The Strategic Initiatives are designed to acheive what the commenter has suggested in terms
of clarity in moving forward on a concise set of actions. Funding comment: The recently formed ECB sub-committee will
address concerns of the commenter. This text has been added and the Partnership appreciates the leadership with the
South Central Caucus to that work. Action assignment comment: The action owners have been clarificed. The
Partnership has a role to identify actions needed whether or they are funded, and we are sensitive to having an Action
Agenda that is substantially unfunded. The owner of the retrofit action was changed. Update frequency comment: The
Partnership agrees that the update work has been time consuming. Our hope is that the Action Agenda structure is
stable and that updates can be focused and simplier. Habitat protection and restoration for salmon habitat is a
strategic initiative and the salmon recovery section has been strengthened and numerous NTAs added. The Partnership
chose to consolidate education and monitoring into Section D and recognizes the cross-cutting nature of these needs.
In the future, that choice could be revisited. The monitoring section will be strengthened for the final. The sub-
strategies were revised to include compliance.




• Reducing the number of strategies and substrategies by combining related ideas.




• Reducing the number of near-term actions and working with action owners to clarify action content and expected
outcomes.
The Partnership acknowledges the need for formal tribal consultation and recognizes at the Partnership structure,
including the LIOs do not change federal trust responsibilities. The Partnership enabling statute does not change the co-
management responsibilities and arrangements that long pre-date the Partnership. The Partnership has and will
continue to work closely with tribes on the Near-term actions, and the tribes are already engaged in helping populate
the strategic initiatives. This effort includes the shellfish bed recovery. Before the Action Agenda is finalized, the
Partnership will actions with NWIFC to make sure that all actions with a co-management responsibility are accurately
reflected. Chris must review this response




The Partnership agrees that federal actions are critically important to Puget Sound recovery and recognizes that federal
efforts are not yet well represented in the Action Agenda.During development of the Action Agenda, federal agencies
participated on the interdisciplinary teams and in other ways, and were focused on responding to the treaty rights at
risk paper. In April and May 2012, the Partnership received a detailed spreadsheet of ongoing federal actions and new
actions, primarily related to a response to the Treaty Rights at Risk Paper, for consideration for the Action Agenda.
Future versions of the Action Agenda can more fully incorporate federal ongoing programs and near-term actions. The
matrix of federal programs and actions will need vetting with other Partners as it is incorporated. Support of federal
programs is called out the Funding Strategy. The suggested table or list of all funding sources could be developed as part
of the funding strategy.
Comments noted. The intent of the Action Agenda is address the types of general concerns raised in this comment.
Commenters are directed to specific sections of the Action Agenda for more details, and the Strategic Initiatives for
more information on near term priorities.
The Strategic Initiatives and an Executive Summary have been added to the Action Agenda. The Action Agenda is a long
document because of the scale and complexity of our ecosystem and we agree that shorter, more accessible summaries
are also needed. The Partnership agrees that using factual data is critically important in establishing priorities. The
Initiative identified in the comment was changed to "Recovery of Shellfish Beds" and includes reducing pollution from
rural and agricultural lands. Runoff problems and actions are described in Section C3 and C7. The Partnership believes
that several social science disciplines are needed to help inform decision making. We welcome discussions with the
Farm Bureau on incorporating social considerations into decision-making. The Partnership has tried for a balance of
regulatory and voluntary actions. This is particularly true in Section C3 (agricultural runoff) where new approaches that
combine regulatory and incentives have emerged. The importance of agriculture and forestry to the overall recovery
effort is identified in Strategy A4 and actions are included for developing comprehensive strategies for both age and
forestry. The Partnership looks forward to working with the Farm Bureau on those efforts.




Partnership staff worked with WSG on their final actions and measures. Academia is listed as a partner in the diagram in
the management conference appendix. A section on academia will be added to the appendix for the final update.




The Partnership always planned to include this responsiveness summary to the public comments. We did not choose to
provide interim comment summaries during the earlier drafting stages.
The Strategic Initiatives and an Executive Summary have been added to the Action Agenda. The Partnership agrees that
accurate local information is important and have worked closely with the Local Integrating Organizations to capture and
reflect their priorities in the both the local profiles and throughout the Action Agenda strategies and sub-strategies. The
intent of the LIOs is bring local interests together and represent collective priorities. The Partnership asked the local
areas to identify these. If there are differences of opinion locally about what to include in the profile, the Partnership
supports local areas to work out those differences. The profiles are uneven in content and level of detail. This is noted
in the Action Agenda and reflects differing stages of development of each LIO. The Partnership identified that the Action
Area scale was appropriate for some local areas (e.g., Strait of Juan de Fuca, Hood Canal) and not others (e.g., the
Whidbey basin was simply too large and diverse for the scale of planning needed). This is also explained in the Action
Agenda. The HCCC is the Local Integrating Organization. The Partnership anticipates that as the IWMP is completed,
their local priorities will be better clarified. The Partnership works closely with the HCCC and the HCCC anticipants one
set of priorities that can be used for both the IWMP and the Action Agenda. Reporting on the Action Agenda is covered
in the State of the Sound. All of the 2008 Actions are considered retired" with this update. Some of those actions are in
the update because they were not started or completed. Implementation of local salmon recovery plans is called out in
Section A6.1. The 2012 Action Agenda makes a significant step forward in accountability by adding outcomes and
performance measures. A for Eliz: At one time, we talked about building a table like they request, but we ran out time
for it and I haven't heard the request again. I would be ok to commit to this for the final . The Strategic Initiatives will
help narrow the two year priorities. That work will now be completed in Summer 2012. The legislative action section
was removed. The need for local funding is called out in the salmon recovery section (see A6.5) and in the funding
section. Collaboration with the Department of Defense on mutually beneficial actions is in the Action Agenda (see
Funding Action E1.2 NTA 2). Light pollution has not been identified as a priority to address, but could be in the future.




The Strategic Initiative concept, Protection and Restoration of Habitat in Support of Salmon Recovery, was agreed up
between the draft Action Agenda and April 2012. This covers more of the salmon recovery plan. The salmon recovery
section of the Action Agenda was significantly revised and several near term actions were added (see Section A6). In
addition, the funding needs for the salmon recovery called out as an action and specifically identified in the funding
strategy. Population of the strategic initiatives, including prioritization, is still being worked out and will be completed in
Summer 2012.
The Partnership agrees that local implementation of actions is critical for success. The Partnership worked closely with
local areas to review and refine their local profiles, to ensure that the profiles describe local areas accurately and fully
reflect the progress each has made to identify and prioritize local strategies and actions. The Partnership recognizes
that funding is essential for implementation. The recently formed EBB funding sub-committee has significant leadership
from local governments to identify how to close the gap between current funding available and need expenditures.

The salmon recovery section was significantly revised (see Section A6) and discussed with the Salmon Recovery Council.




The Strategic Initiatives are intended to produce a narrow list of priorities. From the December, the number of NTAs
was somewhat reduced, although the Partnership received many ideas for new actions. We have worked hard to with
action owners to clarify action content and expected outcomes. For the draft, we wanted to make sure we had the right
list of actions before working in detail on the measures.

The Partnership agrees that local governments are on the front lines of protection and recovery in Puget Sound and
understands the constraints and concerns of local governments. Support for local government implementation is better
identified in the Action Agenda. Continued local government participation on the ECB funding subcommittee will is
important in identifying determine sources and amounts being spent on strategic initiatives compared to the
anticipated amount needed.




In response to this concern the Partnership met with representatives of WSDA multiple times to work to strengthen the
text about the importance of agriculture and to develop a comprehensive agricultural strategy for Puget Sound. (A3.2
NTA 2). The Partnership will continue to work with agricultural community to better ensure those interests in
represented in discussion.
Text of the Hood Canal local profile has been edited to reflect suggestions in the 2nd and 4th bullets of this comment.




Text of the Hood Canal local profile has been edited accordingly. Issues of water quality, low dissolved oxygen and
eutrophication are being addressed as part of the HCCC's Aquatic Rehabilitation Program. Shellfish and shellfishing
(including displacement and potential reintroduction of Olympia oysters) are focal components or targets being
addressed by HCCC's Integrated Watershed Managememt Plan (IWMP). Regarding the 5th bullet, text has been
modified to clarify HCCC's capacity to serve as the LIO but overall structure of the chapter has been retained to ensure
consistency with other Action Area profiles. The list of agencies and organizations are not "random", but rather the
various partners that work with HCCC in developing and implementating actions for ther Hood Canal watershed. All of
these partners are key in developing local strategies and are involved depending on the action, strategy and issue at
hand. Regarding the 6th bullet, HCCC is actively pursuing protection of various wildlands as part of the overall strategy
inherent in the IWMP.




Text of the Hood Canal local profile has been edited accordingly, and the HCCC and its partners are currently working to
prioritize its list of locally-significant strategies and actions, which will continue in 2012 and beyond.




Text of the Hood Canal local profile has been edited accordingly.
HCCC will continue to work with HCEC and other partners in development and implementation of the IWMP.




Text of the Hood Canal local profile has been edited accordingly. HCCC's Aquatic Rehabilitation Programis in the process
of addressing these issues using workgroups comprised of technical experts and regulators. Part of this effort is the
development of a relevant and sustainable monitoring and evaluation program designed to address and augment
corrective actions and management programs.
Text of the Hood Canal local profile has been edited accordingly.




Text of the Hood Canal local profile has been edited accordingly.
Text of the Hood Canal local profile has been edited accordingly. The HCCC's Aquatic Rehabilitation Program is in the
process of addressing all of these issues.




Prioritization of local strategies and actions is still underway through the HCCC's Aquatic Rehabilitation Program and
Integrated Watershed Management Plan development process. Major areas of focus will be determined as this process
continues in 2012 and beyond.
Text of the Hood Canal local profile has been edited accordingly. Thriough the HCCC's Integrated Watershed
Management Plan approach, the local near-term actions referred to will be addressed and considered for
implementation. As the LIO for the Hood Canal action Area, specific actions pertinaining to the Action Area will be
addressed. The details of these actions are greater than what can be summarized in the Action Agenda.




Text of the Hood Canal local profile has been edited accordingly.
Text of the Hood Canal local profile has been edited accordingly, but prioritization of local strategies and actions is still
underway through the HCCC's Integrated Watershed Management Plan development processand the HCCC's Aquatic
Rehabilitation Program. Major areas of focus will be determined as this process continues in 2012 and beyond.




The Partnership appreciates this caution; Ecology is legally responsible for establishing instream flows, was instrumental
in crafting the instream flow near-term actions, and will be responsible for their implementation.




The list of WRIAs was corrected in consultation with Ecology, and identified WDFW as the secondary owner of this NTA.
The Partnership appreciates this review and agrees that local and tribal governments have a critical role to plan in
successful water management. The need to work closely with local and tribal officials is addressed in the intorductory
text to the NTAs and ongoing support for watershed planning groups is addressed in the discussion of key ongoing
activities. A8.1 NTA 3 (now A7.1 NTA 3) has been changed to provides for establishment of water compliance officer
staff positions (instead of water masters) to provide a local compliance presence, protect the resources, support
mitigaiton, reduce ater use, and protect senior rights including instream flows. TIssues around reclaimed water will be
addressed in the reclaimed water rulemaking; we agree that the King County program is an effort that should be
considered. The idea of more holistic watershed and integrated water budgeting and planning based on all water needs
and all potential water resources is included in the list of emerging issues and future opportunties, as is the idea of
additional groundwater resources assessments (water mapping). We were not able to negotiate NTAs on those issues
at this time. Editorial changes and corrections have been made.




The Partnership consulted with Ecology on this suggestion and the Agency did not feel it was ripe for an NTA at this
time. It has been added to the list of future issues for consideration in future Action Agenda updates.




We have refined and clarified the organization of this Section. The language on metering has been addded. The
langauge on basin flow protection and enhancement programs acknowledges that funding is needed (as does the list of
emerging issues/future opportunties for this section); A7.1 NTA 3 provides for establishment of water compliance
officer staff positions to provide a local compliance presence, protect the resources, support mitigaiton, reduce ater
use, and protect senior rights including instream flows. The Partnership did not incorporate an action requesting
establishment of new enforcement authorities to protect and restore flows for the recovery of salmon. We have
strengthened the instream flow NTAs and the NTAs on salmon recovery more generally. Issues around reclaimed water
will be addressed in the reclaimed water rulemaking; we agree that the King County program is an effort that should be
considered. The idea of more holistic watershed and integrated water budgeting and planning based on all water needs
and all potential water resources is included in the list of emerging issues and future opportunties, as is the idea of
additional groundwater resources assessments (water mapping). We were not able to negotiate NTAs on those issues
at this time. Finally we have not included an NTA on assessment of groundwaer usage from the dairy and stockwatering
businessess in Puget Sound at this time.
A discussion of climate change was added to this section. The Partnership does not know of a quantative estimate of
how much each basic approach might contribute to summer stream flow goals, we agree this analysis would be helpful
in considering how best to achieve progress towards targets and will consider it in the process to develop interim
milestones to track progress towards targets which will be carried out after Action Agenda adoption. The idea of a
comprehensive “Puget Sound Water Plan”, which would integrate all of the water issues in the basin, including water
rights, water quality, land use permitting, habitat protection, and watershed management, and provide a mechanism to
deploy relevant programs to increase the likelihood that instream flow targets will be met is discussed in the list of
emerging issues/future opportunities. Similarly, the development of more holistic, watershed and integrated water
budget and planning based approaches that would examine all the water needs in a watershed (e.g., growth,
industry/agriculture, stream flows) and all the potential water resources (e.g., reclaimed water, stormwater, and
rainwater harvesting) and work to best match needs and resources. The Partnership was unable to successfully
negotiate NTAs on either of these issues in this Action Agenda; and in general the interest in additional planning in
Puget Sound is low. The potential for additional work with Canada on the Abbotsford Aquifer is addressed in the list of
emerging issues and future opportunties for potential inclusion in future Action Agenda updates. We have referred the
idea of using third-parties to develop proposals to amend existing in stream flow rules to Ecology for their
consideration.




The Partnership appreciates the support for the concpt of integrated water planning and budgeting, we agree this is
likely to become increasingly impotant and further agree that reclaimed water would be an important componant of a
water plan and budget. We consulted with Ecology on the issue of exempt wells and they believe that the proposed
NTA is the right step to address the exempt well issue in this Action Agenda. Future Action Agenda updates may include
other efforts and if the commenter has specific actions in mind that are needed the Partnership would like to discuss
them. A discussion of climate change was added to this section, the Partnership agrees agrees that consideration of
climate change impacts is important to strategies for freshwater flows and groundwater.



The Parternship appreciates these comments and has removed the proposed NTAs on water demand and water use
conservation to focus on implementaiton of ongoing programs.




The title of this strategy is Protection and Conservation of Freshwater Resources.
This NTA was not developed at this time. It could raised within the Monitoring Program or future updates.




The Partnership appreciates this support for the importance of instream flows. A7.1 NTA 3 addresses water code
compliance and enforcement and calls for establishment of compliance officers who would provide a local compliance
presence, protect the resource, support mitigation, reduce water use, and protect senior water rights including
instream flows. The idea of developing more holistic, watershed and integrated water budget and planning based
approaches that would examine all the water needs in a watershed (e.g., growth, industry/agriculture, stream flows)
and all the potential water resources (e.g., reclaimed water, stormwater, and rainwater harvesting) and work to best
match needs and resources is addressed in the list of emerging issues and future opportunities. The Partnership would
welcome additional discussion with the Tribe on how it can best support appropriate use of all water sources to help
support instream flows.




The Partnership has revised the descriptions of local strategies to be consistent with updated information provided by
the local areas.




The idea of use of water acquisition to improve flows has been added to the list of emerging issues and future
opportunities. The Partnership agrees it is an important tool for flow enhancement. We have added a footnote to
clairfy the status of the Dungeness River flows.




The Partnership agrees that local and tribal governments have a critical role to plan in successful water management.
The need to work closely with local and tribal officials is addressed in the intorductory text to the NTAs and ongoing
support for watershed planning groups is addressed in the discussion of key ongoing activities.
No change made.




We have added collabortation and coordination with Canadian agencies as a key element of a successful strategy for
managing invasive species.



The Washington Invasive Species Council web page provides a coordinated mapped product for the Council's top 10
invasive species and will expand this producted to include knotweed over the next two years. Please visit
http://www.invasivespecies.wa.gov/council_projects/epa_grant.shtml
We have added a discussion of climate change to this section. The agency owner does not have adequate capacity to
accelerate the risk assessment task even though an advanced delivery date is desirable. Note that all of the strategies
and actions on invasives have been consolidated into one section, B5.




The Partnership appreciates this support for invasive species efforts.




We have added a reference to collaboration with USDA. Note that the invasive species strategies and actions have been
consolidated so they no occur in a single section, B5.
Explained in new Whidbey Basin profile information
Current population of county: EPA is fact checking
Work is still being done ot refine the strategies and actions by the LIO. This is likely to be included after the LC
adoption.

RE: port susan MSA vs Smith/Minor - PSP will provide this comment to the LIO for consideration.



Island LIO is working to provide updated thinking about the prioritization process.




Thank you, complete.



The Partnership has strengthened the language on special designations and included reference, and support, for the the
specific designations discussed in comments in the ongoing programs section of A2. They could be reconsidered as NTAs
in the future.
The Partnership is sensitive to concerns about creating additional layers of duplicative coordination or analysis, and we
are continuing to work with partners to create a bias for action throughout the Action Agenda. We agree with the
observation that under GMA local governments must balance environmental protection needs with the requirement to
adequately provide for growth, and we do not see the near-term actions as inconsistent with GMA, rather the intent is
to work with local government to optimize implementation of GMA and SMA. Proposed A1.1 NTA 1 has been deleted.
Proposed A1.2 NTA 2 has been revised to clarify that the intent is to, working with local governments, identify barriers
to incorporating policies consistent with the Action Agenda and to identify best practices and assistance needed to
overcome these barriers. The identification of barriers (which will include discussion of gaps, if any) will occur before
the development of any example policies. The result of this effort will be example (not model) policies that include best
practices consistent with Puget Sound protection and recovery and existing GMA and SMA requirements. The
Partnership acknowledges AWB's ongoing concern about the land cover target, and will continue to find ways to
improve the target in the future.




The Partnership is sensitive to concerns about creating additional layers of duplicative coordination or analysis. We
agree with the observation that under GMA local governments must balance environmental protection needs with the
requirement to adequately provide for growth, and they need flexibility to do so. We do not see the near-term actions
as inconsistent with GMA, rather the intent is to work with local government to optimize implementation of GMA and
SMA. Proposed A1.1 NTA 1 has been deleted. Proposed A1.2 NTA 2 and NTA 3 have been combined and revised to
clarify that the intent is to, working with local governments, identify barriers to incorporating policies consistent with
the Action Agenda and to identify best practices and assistance needed to overcome these barriers. The identification
of barriers (which will include discussion of gaps, if any) will occur before the development of any example policies. The
result of this effort will be example (not model) policies that include best practices consistent with Puget Sound
protection and recovery and existing GMA and SMA requirements. Proposed A1.4 NTA 1 was deleted and the concept
moved to the future opportunities section.
The edits and editorial corrections have all been made and the NTA language updated. We note that the final land
development NTAs that are owned by Commerce were carefully negotiated with the agency and incorporate agency
comments. The Salmon Recovery "text box" was updated to more accurately refer to the ongoing federal response
process.
Corrections to descriptions of ongoing programs have been made. We agree that B1 is the appropriate place to
address nearshore protection and strategies and actions related to nearshore protection are consolidated there. It is
not possible to remove all reference to SMA planning from the land development section (nor do we believe that was
the suggestion); we have added cross-reference to B1 in the A1 NTAs to ensure this connection is made.
Corrections to descriptions of ongoing programs have been made. A1.1 NTA 2 was deleted. Proposed A3.2 NTA 1 is
now A3.1 NTA 3; the performance measure is consistent with subsequent edits provided later by DNR. A1.2 NTA 3 (now
addressed A1.2 NTA 1) was revised and includes reference to water quality.
Corrections to descriptions of ongoing programs have been made. After further discussions with Ecology and
Commerce, an general NTA on funding pilot projects to accomplish land development strategies was not added.
Reference to the National Estuary Program Watershed Grant was added to the introductory language including the
statement that "Ecology and Commerce, the lead agencies for that grant, will continue to fund and provide technical
support for pilot projects at the local level aimed at implementation of these sub-strategies." A1.2 NTA 2 and 3 were
combined. An NTA on Ecology and Commerce providing support and funding for local projects to identify and
implement landowner incentives including TDRs and ecosystem services markets was added (A3.1 NTA 2). The NTA on a
regional sustainable community program was revised to clarify that the first step will be program scoping.




Comment noted. The owners of these actions can help connect the results to the MSP efforts.
We have worked to clarify the NTA language in response to this and other comments. The actions in the Action Agenda
are not the same as those listed in the BSWP. In addition, the actions in the Action Agenda have owners who have
agreed to report on progress. The BSWP does not yet have that type of tracking element.




We appreciate the support for many of the land development strategies and actions, particularly those related to
spatial landscape data collection and sharing, decision support, and ecosystem markets. As the conservation markets
develop, we would welcome learning from our Canadian partners. The Partnership recognizes the value of fine scale
mapping. We welcome collaboration with Canada on spatial landscape data.
 Text on the PSWC project and its status and the text on stream-typing have been clarified. A1.1 NTA 1 was deleted and
the idea of a decision-framework was clarified and incorporated into a broader NTA on use of the PSWC to make
decisions. The Science need previously identified in A1.1 was deleted, Section B addresses integration of these data in
more detail. A description of the PSRC was added. We did not add a table of permitting programs at this time, but it
could be added in the future. A1.4 NTA 1 on a comprehensive assessment of no net loss was deleted. Individual
projects are not typically listed as NTAs (e.g., the salmon recovery three year work plans are included as NTAs). Large
scale projects spanning multiple local areas such as the Port Gamble action may warrant being called out individually.
Support for wild and scenic and wilderness designations, including to the referenced areas, was added to the discussion
of ongoing programs. The text on forest conversation was edited, and discussions of climate change and its relevance
to agricultural lands was added. Implementation of GMA and SMA including identification of barriers to implementing
policies consistent with the Action Agenda, and identifying strategies to overcome those barriers, and example best
practices is addressed in A1.2 NTA 1.




Climate change is incorporated throughout the Action Agenda, and incorportated into NTAs where possible. The
Partnership appreciates the support for use of Ecology's watershed characterization tools and the other data sets;
implementation guidance for use of the tool, and solution templates will be addressed by the Watershed
Characterization Technical Assistance Team, A1.1 NTA 1 has been revised to clarify that the decisions contemplated are
watershed planning and land use decision by local governments. A1.4 NTA 1 on a cumulative evaluation of no net loss
has been deleted. The A2.1 NTA 2 (now A2.1 NTA 4) has been strengthened in both the substance and the measure of
the action. A2.1 NTA 3 (now A2.1 NTA 1) has been retained at the request of DNR. A2.1 NTA 5 and A2.1 NTA 6 have
been combined and clarified. We appreciate the support for use of special designations and have expanded the
discussion of those programs in the text. Editorial comments incorporated.
The Partnership appreciates this support for the efforts around preservation in Port Gamble Bay. The action on this
effort for Forterra has been retained, the leveraging action was dropped.




The Partnership appreciates this support for land development strategies. We have worked closely with the HCCC and
the West Sound (North Central) LIO to incorporate their priority strategies and actions into the action area profiles.
An NTA on supporting implementation of the VSP was added to Section C4 (the strategy for agricultural runoff).




The Action Agenda does not call for changing the SMP guidelines to reference the recovery targets because it is a
statewide program. However, identify ways to incorporate the targets into the review process could be considered in
the future. Statewide programs such as the SMP A1.4 (now A1.3) has been clarified to read "improve, strengthen and
streamline implementation and enforcement of laws. . .." We do not believe that A3.3 NTA 1 (on a strategy for
retaining economical viable and long-term successful working forestlands) duplicates the VSP program, but agree that
consideration of the role of the VSP will be important to both the forest land and the similar agricultural land strategies
contemplated in the Action Agenda. Finally, we have not contemplated in this Action Agenda any mechanism to
"compel" local governments to adopt model ordinances, that type of action would be inconsistent with the non-
regulatory nature of the Partnership, and it is not supported by other partners. We have provided a number of actions
meant to incentives and support local government decision making and the balancing of the many requirements of the
GMA and SMP that local governments must achieve, for example, A1.2 NTA 2 calls for financial support for GMA
updates.




The NTA on model ordinances was revised to refer instead to "example best practices." We agree that in
implementation of existing programs is where the most immediate opportunities for streamlining exist and have
clarified A1.3 to refer specifically to streamlining implementation. We appreciate the support for watershed planning
and characterization tools.
The Partnership is sensitive to concerns about creating additional layers of duplicative coordination or analysis, and we
are continuing to work with partners to create a bias for action throughout the Action Agenda. We agree with the
observation that under GMA local governments must balance environmental protection needs with the requirement to
adequately provide for growth, and they need flexibility to do so. We do not see the near-term actions as inconsistent
with GMA, rather the intent is to work with local government to optimize implementation of GMA and SMA. Proposed
A1.1 NTA 1 has been deleted. Proposed A1.2 NTA 2 and NTA 3 have been combined and revised to clarify that the
intent is to, working with local governments, identify barriers to incorporating policies consistent with the Action
Agenda and to identify best practices and assistance needed to overcome these barriers. The identification of barriers
(which will include discussion of gaps, if any) will occur before the development of any example policies. The result of
this effort will be example (not model) policies that include best practices consistent with Puget Sound protection and
recovery and existing GMA and SMA requirements. Proposed A1.4 NTA 1 was deleted.




The ranking process for sub-strategies which is based on expected ecological impacts addresses this issue in part. The
guidance on how to use the Action Agenda to help make funding decisions also addresses this issue.


The watershed characterization work referred to in A1.1 is being carried out by state agencies and will be provided by
them as a tool that local government can use for GMA and SMA updates. The combination of the characterization
information and the decision support tools/solution templates to be developed will provide a science basis for decisions
that local governments could choose to rely on. We have revised A1.2 NTA 2 (now A1.2 NTA 1) to refer to "example
best practices" and policies, rather than model ordinances, to address concerns about "models." A1.2 NTA 3 (now A1.2
NTA 1) has been retained and we agree that participation by local jurisdictions will be critical to this action. A1.3 NTA 1
(now A1.2 NTA 2) has been retained; we are not proposing rewriting GMA and SMA at this time. A1.4 NTA 1 has been
deleted. We appreciate the support for A2 and A3 and agree that funding for local governments is necessary and that
TDR and other similar strategies are important tools for protecting Puget Sound. We have retained A4.2 and A4.3 (now
A4.1 and A4.2).




Land acquisition is addressed in A2 which includes a near-term action on development of a funding mechanism to
acquire properties at imminent risk of conversion.
Support for these actions is noted. The near-term actions on development of example planning policies have been
revised to clarify that example policies will consistent with Puget Sound protection and recovery targets and GMA and
SMA requirements (See A1.2 NTA 1). The idea of Ecology and Commerce providing additional direction where programs
are inconsistent was not developed as a near-term action and has been added to the future opportunities section.




Proposed A1.2 NTA 2 and 3 have been combined and the language has been refined to clarify that the focus is on
finding examples of policies and best practices that work both to make progress towards Puget Sound protection and
recovery targets and meet GMA and SMA requirements. The Partnership agrees that local governments need to be part
of the process to develop ecosystem protection standards and grant criteria and selection.
The Partnership appreciates these comments but does not agree that the responsibility for promoting a broad partner
discussion of ways to support state funding for local governments GMA implementation should be given to an NGO
instead of the Department of Commerce, the state agency responsible for GMA oversight; we beleive that NGOs should
participate in the discussion and support local government GMA funding as appropriate. Additional language has been
added to the Action Agenda introduction to describe the purpose and the placement of the target views and the target
views themselves have been refined and clarified.




The separate list of legislative actions was deleted. The Partnership addresses this issue in substrategy A4: Encourage
compact regional growth patterns and create dense, attractive and mixed-use and transit-oriented communities. The
need to consider funding allocations is identified in the Funding Strategy future opportunities section.



The legal and regularatory protection elements are in Strategy A1; land acquisition and easements presented in A2.
The importance of local information and characterizations in identifying and prioritizing land for protection or
restoration or low impact development as been added to the discussion in A1.1. A1.3 and A1.4 have been combined
into a new A1.2 and it includes an NTA on supporting funding for local governments GMA implementation. Lack of
funding is an overall implementaiton issue for the Action Agenda. The need to protect ecologically sensitive areas as
designated in critical area ordinances and shoreline management programs has been added to the ongoing program
description in A2.3
We agree that appropriate density must be encouraged, A4.1 NTA 1 on a regional sustainable communities program
and sub-strategy A4.2 on infrastructure incentives in urban growth areas reinforce this. In recent conversations the ECB
has taken up the issue of density which will hopefully can bear fruit for legislative strategies or for the next Action
Agenda update. Implementation of the Puget Sound Salmon Recovery Plan is addressed in A6.1 NTA 1.




The Partnership will work with Ecology to ensure that information on the watershed characterization results are
presented to tribes and local watershed groups; the watershed characterization documents developed to date have
been provided for peer review and public comment as they have been developed. An action for the Partnership to
address restoration permit barriers was added as A6.1 NTA 2. The effectiveness of regulatory actions and issues with
restoration funding being prioritized over acquistion were not advanced as a near-term actions and are included in the
future considerations section. The Partnership agrees that finding solutions that address both habitat and farming
needs is important. Action A3.2 NTA 2 was added to find mutually beneficial solutions. The funding mechanism for
rapid aquistion is now A2.1 NTA 4. This action will be advanced through the ECB funding subcommittee as identified in
the Funding Strategy. The Partnership will also discuss the advancement of this action with partners.




Comment noted. A1.4 NTA 1 has been deleted.



 Wild and Scenic Designations are listed as an example tool. The Partnership agrees that this tool may have
considerations that would limit its effectiveness in some circumstances. Addressing these issues may be needed on
local level. The Partnership notes the concern about the land cover target. The Leadership Council will revisit recovery
targets in the future. The importance of local plans in the characterization process has been added to the text. We
agree that integration of local recovery plans will be important to understanding priorities for protection, restoration
and development and have incorporated references to them in the text describing A1.1 and in Section A6.
Prairie oak and woodland restoration was added as A2.2 NTA 1.




Reference to UW Sea Grant was removed as requested.



We have added references to other data sets and to use of more local data, including the watershed chapters of the
Puget Sound Salmon Recovery Plan to the text on A1.1. The need for continued improvement in the stream typing maps
and uses is called out under future considerations.




The Partnership agrees that the use of CREP should be expanded, part of the performance measure on A3.1 NTA 1
which deals with CREP is to "identify opportunities for improvements to agriculture conservation programs funding."
The importance of public-private cooperation, A3.1 NTA 2 addresses landowner incentives. Protection of intact areas is
an ecological principle in the Action Agenda and the ECB has reinforced this principle during the prioritization process.
The final actions owned by the Conservation Commission are the result of negotiations with the agency and agency
comments were incorporated. The Partnership has retained ownership for the NTA on development of an agricultural
strategy as a more neutral party. DNR requested to lead the working forest land strategy. WSCC involvement will be
important to both efforts.




The Partnership agrees that development of an agricultural strategy is a very important next step for Puget Sound
protection and recovery. The final wording of the NTA was negotiated with PSP and WSDA. The Partnership agrees with
need to include a broad range of partners in this discussion.




The Partnership agrees that maintaining and enhancing the viability of natural resource industries like agriculture and
forestry is an important part of Puget Sound protection and recovery and appreciates this support for some of the land
development strategies. Strategy A3 is designed to call this out. We anticipate that the Farm Bureau would participate
in development of the agricultural strategy contemplated by A3.2 NTA 2.
Action A1. 2 NTA 1 and Sub-strategy A1.3 were edited. The upland and freshwater restoration strategies and actions
(formerly addressed in A6) are integrated into A2 and some near-term actions have been added in part based on the
work of local areas. Not all sub-strategies have NTAs as implementation of ongoing work is the important action.



No change made.




These edits were made as requested.



These edits were made as requested.


The invasive species strategies and actions have been consolidated into one section, B5.



The Partnership will take this suggestion into consideration for future action agenda updates; at this time there is not
capacity to increase field inspections of vessels.
Expect PSP Salmon Team to supply content for that recovery plan. May consult Feds re: NOAA USFWS involvement in
broadening to include protection, etc. beyond "restoration". PSP will mention the 2011 recs and refer to NTA on oil spill
prevention and risk reduction that relates directly to the recs. in the 2011 Orca plan by NOAA.




The Partnership is not intending to usurp local control in the marine/nearshore strategies and actions. On the contrary,
numerous strategies and actions point to efforts to support local decision-making and implmenetation of existing
requirements, e.g., B1.2 NTA 1 on providing support for updating shoreline master programs.

B1.1 NTA 2 on marine spatial planning is not intended to supercede local control and has been retained in the final
Action Agenda.

Edits and refinments have been made to Section B2; the Partnership respectfully disagrees that strategies and actions
related to protecting and conserving relatively intact ecosystems should be wholesale deleted from the Action Agenda.
We note that a number of actions in this section are local actions, which were contributed by local integrating
organizations to reflect their priorities.

The Partnership appreciates the support for use of incentives to promote shoreline restoration; we note that proposed
B3.2 NTA 1 and 2 on homeowner incentives have been combined into B2.3 NTA 1.
Comments noted. Comments interpreted to be supportive of protection and restoration actions and not a request for
edits.




DFW has statutory obligation to do HPA review; opportunities to streamline HPA through coordination with the US
Army Corps permit process can be considered as part of the implementation of B1.3 NTA 2 on revising the Hydraulic
Code rules to clarify conditions under which hydraulic projects must be conducted.
Strategies and sub-strategies in Sections B1-3 were simplified and clarified.

B 1.1 An NTA on documenting priority areas for protection, restoration, enhancment, and managed growth was added
as recommended. See B1.1 NTA 1. The basin characterization was added to the ongoing program list.

B1.2 monitoring comment: monitoring actions rel consolidated into a monitoring discussion in Section D of the Action
Agenda. The final Action Agenda will have a more robust discussion of the monitoring program.

The biodiversity section was edited (Section B5). Species recovery plan actions were revised in discussions with DFW.


B2.2 NTA 1 was added to address a DFW comment about implementation of PSNERP projects.
B1.1.1 wording substantially revised. The NTAs on marine spatial planning were revised and negotiated with the
agencies and are now in B1.1 NTA 2 which deals with identifying human use patters to support marine spatial planning
and development of marine protected areas and B3.1 NTA 1 which deals with and evaluation of MPA effectiveness.

The list of targets was expanded to include those most closely related to marine and the marine nearshore
environments. DNR's Landscape Prioritization work was added. MRC name was corrected. B.2.1.1 comment: The 10%
figure refers to 19 of 38 highest potential shorelines in Cereghino/PSNERP Strategies document under threat of
development - so permanent protetion of 2 would support the qualitative component of PSP armoring target. And if
repeated biannually, will protect 50% of such by 2020. B.2.1.2 comment: Language negotiated with Ecology. "Aquatic
reserves" will be added to the list now on page 121 for the final Action Agenda.




Technical corrections made and ongoing efforts clarified (and when needed) added to the list of key ongoing program
activites. They are ongoing, not new NTAs.
The NTAs on marine spatial planning were revised and negotiated with the agencies and are now in B1.1 NTA 2 which
deals with identifying human use patters to support marine spatial planning and development of marine protected
areas adn B3.1 NTA 1 which deals with and evaluation of MPA effectiveness. The Partnership appreciates, but chose
not to add the suggestion for additional context to be added to the MSP discussion.

With respect to working waterfronts, the text of the Action Agenda is consistent with that of the commenter and the
MSP recommendations. In working with the Ports, the Partnership was not able to identify near-term actions and work
is focused on ongoing programs. The Partnership did not choose to spend time on developing access NTAs, but lists
suggestions for future consideration.




A mention that MPA planning should stay connected to terrestrial planning will be added to the introduction of the final
Action Agenda. The Partnership did not expand the actions as requested. A specific action could be considered for
future updates.
B2.3 NTA 1 was added to help fill the gap identified by the commenter. Regulatory reform is identified in B1.3 NTA.
Additional ideas for consideration are listed in the future opportunities. The B1.2 NTAs were reworded. The Partnership
does not tell local governments whether to conduct updates with staff or consultants. Sub-strategy B3.1 about marine
protected areas was reworded. The ongoing program list can be expanded in the future. These cautions suggested are
part of implementation of the action. B1.2 NTA2 (now NTA 1): Language still under discussion with Ecology. B2.2 NTA1
(now B1.3 NTA 1): Final wording negotiated with DFW. Adding SLR is problematic for adoption of the rule at this time.
B3.1 NTA1 (now B2.2 NTA 1) Significantly revised in content. B3.1 NTA1 was deleted at the request of DNR. B3.2 NTAs 1
and 2 were deleted as drafted and replaced with new B.23 NTA 1. B3 was revised and better reflects the concern of the
commenter. The final wording of B2.2 NTA 4 about creosote pilings was negotiated with DNR. B2.2 NTA 2: language
was revised in negotiations with State Parks. The Deschutes Estuary Project is not mentioned by name in the Action
Agenda. If may be covered by Strategy A6.1 if identified as a local priority.
B1.1.1 is to be reinstated (PSNERP/shoreline inventory/salmon recovery priorities reconciliation) per comment. B1.3,
LNTA 1 - we'll seek clarification on permit. B2.1, NTA 2 Ecology (&REnton) seeks that first part be retained, and the
second had a number of comments seeking that ECY guidance be parallel to PSP shoreline armoring target - so decided
to retain both because related in this one NTA (splitting would increase overall # of NTAs and might cloud priortization
result). B2.3 (page 125) – "An NTA should be created to address permanent removal of armoring" - PSP committed to
lead an incentives NTA to promote permanent removal of armoring (via structure setback) to avoid replacement of
armoring. "B2.5 NTA 1 is incomplete." clipped/missing text at end of sentence has been added back. B2.6 NTA 1 - no
owner, so eliminated. "B 3.3 (page 138) - There is again reference to restoration priorities being identified in B 1.1 when
this activity does not exist there.
The activity referenced in the last bullet at the bottom of the page page 139 is not yet happening and should be
captured in an NTA instead of an “ongoing” activity." - B1.1.1 is to be added back so the reference will make sense; and
the bottom bullet is now to be a separate NTA (The Northwest Straits Commission and WDFW will work with DNR,
tribes, fishers and others to remove remaining derelict nets near shore in Puget Sound by December 2013, resulting in
complete removal of approximately 500 known legacy nets.) with NW Straits listed first.




The Partnership appreciates the suggestion about improving the discussions of ongoing programs and will take it into
consideration for future Action Agenda updates.

B2.2 NTA 4 has been added to address creosote piling inventory and removal particularly near important herring
spawning beds. The wording was negotiated with DNR.




The Partnership apprecites the support for its role in promoting local implementation. In responding to comments we
have worked to better balance the NTAs in both land development and marine/nearshore to present a mix of incentive-
based approaches and optimization of existing regulatory approaches.
B1.1, NTA 2: NTA does not imply that MSP supercedes local control. B2.6 NTA 1 was deleted for some of the reasons
identified by the commenter. B3.2 NTA 1 and NTA 2 were deleted due to lack of ownership. B.23 NTA 1 is a
replacement incentive action.




B2.3 NTA 1 is for homeowner incentives, HPA related actions are B1.3 NTAs 1 and 2. An action to work with BNSF is in
A6.1. The Partnership agrees that working with the tribes on MPAs is critically important. Marine management area was
not called out but is implied by the e.g. The Partnership actions that action now is essential and understands that
funding is needed. The Action Agenda does not imply delay for action.
Geoduck was removed from the list.




Climate change information was added to this section. Strategies and sub-strategies in Sections B1-B3 were simplified
and clarified and address some of the structural concerns identified by the commenter. Mention of the ongoing work of
the NWSC was added to B1.1, B1.2, B2.1, and B3.2. Because of the reorganization, some issues where NWSC works may
have been unintentionally missed. Monitoring actions are consolidated into Section D4. A more robust monitoring
section will be added for the final Action Agenda. The SoundIQ web application should be discussed with PSEMP in
relation to the monitoring workgroups. The outreach and education section was consolidated into Sections D5-7. The
Partnership relies on the LIOs to identify local work to call out. The text were placed with the table at the beginning of
Secton B1-3. The name correction was made. The suggested education NTA was not added as this section was
reorganized that portion was deleted. B1. 2. STRT 4 was identified locally. The Partnership relied on the LIO to provide
the action. NWS was added to the list of implementers in B2.4 and the formatting will be corrected for the final Action
Agenda. The suggested eelgrass was too general and the no anchor zone idea did not have traction with other partners.
It could be developed if supported by DNR and others. Local priority leads are being developed through the LIO process.
The MRCs could provide the information suggested via that process. The introductory text to B3.2 was clarified.
Overwater structure (B2.1 NTA 3) and state owned aquatic land actions (B2.2 NTA 3): final wording was negotiated with
DNR. Parks is not the owner. The final wording for B2.2 NTA 2 2 was negotiated with Parks.




Comments of support noted.
Return of B1.1.1 should foster protection/restoration of priorities. First sentence in NTA 2.1.2 has been retained due to
this suggestion (EPA commented that split or elimination).




Potential regulatory changes are identified in B1.3 NTA 2. WDFW was not able to incorporate SLR into the revision at
this time. B3.1 NTA related to MPA effectiveness was rewritten with PSP as the owner. The work by TNC was already
conducted (not a call for a new RFP). For substrategy B3.3, additional or other NTAs could be developed in the future.
Strategies and sub-strategies in B1-B3 were clarified with revisions to NTAs to clarify outcomes and ownership.
Implementation funding, including mitigation funding is discussed in the Funding Section. Implementation of the
salmon recovery three year work plans was added to Section B2. Funding for local governments is included in this
section.
Sub-strategies in B1-3 were simplified and clarifed. They better emphasize enforcement of existing laws. Funding for
local government action is included (B1.2 NTA 1) and improvement in of the HPA is covered in B1.3 NTA 1 and NTA 2.
Work to advance civil complaints as identified was not advanced in the Action Agenda and would need more support in
the broader partnership to do so.




The Partnership agrees that any MSP or MPA creation requires collaboration and work with tribes. The NTA B3.1 NTA 1
about evaluating the effectiveness of MPAs.




While not selected as a strategic intitiative, the "retreat" ideas was developed into B2.3 NTA 1. B.2.1 NTA1: PSP will take
lead. B.2.4 NTA 3: NTA editted to refer to Aquatic Habitat Guidelines Interagency Work group. B3.1 NTA1: Action
revised with DFW as lead. B.3.2 NTAs 1 and 2: Actions were deleted. B3.4 NTAs 1 and 2: Actions with other
implementers could be developed in the future.
Text clarified. The prior list of on page 118 was deleted when the section was simplified. The Partnership would be
willing to list Sea Grant if the appropriate locations are identified.




Comments of support noted. Coordination with Canada is covered in the Management Conference Appendix.




Fagergren concurs (TH too) will remove geoduck from list.



PSP understands comment on circularity. TH did not write this section but will revise the Orca portion. NOAA's 2011
plan IDs a number of “Tasks” set at priority level 1 (highest of 3); they assign oil spills to category: 2.1 Minimize the risk
of large oil spills, which nests under: 2.1.1 Prevent oil spills at Priority 1. Latter only lists ongoing programs. This AA has
oil spill NTA for: reducing risk of catastrophic spill in Orca’s core area of critical habitat (per Felleman-FOE comment)-
illustrates PSP's focus/priority on this element of NOAA plan/task for work in next two years. Will update text
accordingly. Page 155. Will add new NTA on prioritizing creosote piling removal from priority herring sites, perhaps
protection of Port Gamble Bay NTA as important herring spawning site.




Will have to revise biodiversity plan text. Will add or allude to NTAs on herring/creosote piling removal, perhaps
protection of Port Gamble spawning site.
We have added more information on the existing recovery plans and on the many ongong programs to address species
protection and recovery. We agree that this is an area where further improvements can be made in future Action
Agenda updates.




Additional informaiton on marine birds has been added; FWS and NOAA work to prioritize implementation of
restoration and recovery plans will be added when Federal actions are integrated into the Action Agenda.




We have made revisions to logic model diagrams in an attempt to make them more legible.

We recognize that these diagrams are complex yet do not readily convey which actions have the most impact on
outcomes. All strategies and sub-strategies depicted in these diagrams and mentioned in the text of target view
sections are all thought to be directly or importantly linked to the target based on the sub-strategy evaluations
conducted by partners in March 2012. (This method of associating sub-strategies with targets revised our presentation
of the sub-strategies that are most relevant to the shoreline armoring target.)

No change was made to include language in each Target View to recount the indicator development and target
selection process. We agree that this information is important to help the reader understand the context of the
presentation of target-focused information and presentation of sub-strategies based on their expected results on
targets but we have made the judgment that this detail is more appropriately presented elsewhere in Partnership
materials (i.e., vital signs presentations, State of the Sound).

The lack of alignment in land development results chain presentation of intermediate results and actions may reflect a
disconnect between the results expected as key elements of a strategy and the actions included in the Action Agenda.
We note that this lack of alignment was not addressed as the Action Agenda was finalized -- interdisciplinary teams
were not convened in winter 2012 -- but should be addressed as we establish interim milestones and revise
implementation strategies for the 2013 update of the Action Agenda

The placement of the estuaries target view was re-evaluated based on this comment.

No change was made to results chain diagrams to depict strategies that are relatively easy to implement, which require
dedicated focus, and which may not be implemented. This type of discrimination will be considered for use of these
diagrams and for revision and presentation of diagrams in the future.

Target view for eelgrass: no change was made re: implications of weed board declaration of Z. japonica a noxious weed.

We concur with the observed challenge related to the herring target and with the suggestion to undertake a thorough
review of strategies and NTAs. It is our judgment that this can best be accomplished as an adaptation step after the
We have made changes to target views intended to make them more legible; we acknolwedge that these diagrams offer
considerable more opportunities for improvements but believe these presentations are helpful in depicting the linkages
between strategies and targets. We disagree that comment the lack of an institutional analysis means that the
depicted theory of change is "clearly incomplete and flawed." We acknowledge that planning for recovery would
benefit from this type of analysis, and contemporary information about successes and challenges in implementing key
programs and activities, but expect that this information can be used to adapt the strategic efforts depicted by the 2012
Action Agenda rather than be viewed as an essential piece of information for ecosystem recovery planning in 2012.

We have added orca and herring target view diagrams, depicting the Action Agenda's key strategies and sub-strategies
for achieving these targets.




Changes to results chains were implemented to try to improve their legibility. In the text diagrams are presented for
each strategy and for each target.

Intermediate result for large OSS was changed as suggested. The title of the target vew was changed as was the text
about what is presented in the results chain diagram.

The title for C5.3 used in the graphics is the same as the sub-strategy -- refers to funding for small OSS and for locall OSS
programs.

No change was made to convert "large OSS" to "LOSS" since it's not clear that the acronym is understood by readers or
conveys substantially more/different than large OSS. In our terminology OSS refers to either small or large depending
on the qualifier and/or the context. PSP staff may need to revisit this if LOSS is regionally understood to be the better
terminology.
We agree that adding interim milestones (the commenter said benchmarks) will complete the picture.

No changes were made related to the comment about Partnership's adopted targets based on Ecology's SQTI and SCI.
As Partnership staff worked with Ecology representatives during the June 2011 Leadership Council discussion of this
target, the Partnership became aware of the difficulties of (mis)interpretation of the SCI, SQTI results; PSP has and will
emphasize that its targets are based on evaluation of regions and bays based on ambient monitoring findings. This does
not give the same picture, and is not focused on the same detailed characterizations, that identify clean up site. PSP
would like to continue working with Ecology to ensure that vital signs information in other documents and in our on-line
presentations is offering all the clarity suggested in Ecology's comment.

The two simple changes for pages 269 & 270 were made as suggested. Rather than include additional figures and
considerable additional text in the marine sediment quality target view, we have elected to report the conclusion
available from the detailed information presented in the Ecology comments but to present those detailed findings
elsewhere (e.g., in PSP and Ecology presentations about the marine sediment quality vital sign.)




We acknowledge the important concept conveyed in this comment and expect that depicting relationships between
actions and goals will be just the first step in understanding and adjusting actions to better aim efforts at the targets we
have adopted. The target views are an attempt to depict the contributions of the Action Agenda strategies to achieving
the targets; these target views will need to be used (i.e., in the process of adopting interim milestones for each target
and in the 2013 revision of the Action Agenda) to evaluate the Action Agenda contributions and the "likelihood of
reaching the targets based on the" adopted actions.

No change. This comment will be shared with PSP staff and the particpants in the PSEMP work groups to encourage
better communication and collaboration across the Salish Sea.
Action Agenda presentations of results chains were not significantly changed for the final spring 2012 version. We hope
that this consistent depiction of "results chains" as means of depicting the logic of strategies and sub-strategies, and the
complex set of contributions to achieving each target, will help to orient the reader to each section of the text. We
have chosen to present target views interspersed within the framework strategy of the document to illustrate how the
achieving the target is viewed as a combined effort of multiple strategies. It seems important to keep this material in the
body of the document (rather than in an appendix) to satisfy interests (expressed by board members and JLARC
performance auditors) that the Action Agenda depict and clarify the relationships among the Partnership's goals and
the strategies and actions presented in the Action Agenda.

As in the December 2011 draft, the more detailed results chains for each strategy -- i.e., those to represent each sub-
strategy and its near-term actions -- are shown in an appendix.

Future versions of the results chains can be annotated with future desired conditions beyond 2020. We recognize that
a number of the 2020 ecosystem recovery targets do not represent a "healthy," functioning system, but in most cases
we have not yet articulated the future (beyond 2020) desired ecosystem condition.

Strategies and sub-strategies are depicted in the results chain diagrams using the titles developed for presentation in
the text. This approach may not depict the forward momentum intended by each strategy but should make it easier
for the reader see expected results and interactions among the elements of a strategy introduced in the text. When it
The introduction to this target view was revised to clarify the goal for Chinook populations and the current status of
these populations.



Strategies and sub-strategies depicted in target view results chain diagrams and mentioned in the text of target view
sections are those thought to be directly or importantly linked to the target based on the sub-strategy evaluations
conducted by partners in March 2012. Sub-strategies are depicted in the target view sections if they were (a) identified
by at least 80% (or 78% in the case of the estuary target) of respondents as having a direct link to the relevant ecoystem
components or (b) for targets representing ecosystem pressures, received a score of at least 0.33 (or 0.50 if the target is
represented by more than one pressure), where the score is the product of the inverse of the average rating (minimum
0, maximum 1) and the proportion of respondents who rated this pressure among the top five pressures affecting the
sub-strategy under evaluation.


Results chain presentations have been revised somewhat in hopes that they can be more readable in the text. We
recognize that these documents are already depicting many "interconnected and complex" relationships and yet "do
not readily convey which actions have the most impact on outcomes." Strategies and sub-strategies depicted in these
diagrams and mentioned in the text of target view sections are all thought to be directly or importantly linked to the
target based on the sub-strategy evaluations conducted by partners in March 2012. Sub-strategies are depicted in the
target view sections if they were (a) identified by at least 80% (or 78% in the case of the estuary target) of respondents
as having a direct link to the relevant ecoystem components or (b) for targets representing ecosystem pressures,
received a score of at least 0.33 (or 0.50 if the target is represented by more than one pressure), where the score is the
product of the inverse of the average rating (minimum 0, maximum 1) and the proportion of respondents who rated
this pressure among the top five pressures affecting the sub-strategy under evaluation.

No change was made in the discussion of the on-sites target. PSP staff interpret the Partnership's target about
expanding designations of marine recovery areas or their equivalent as a recognition by the Leadership Council that
special (MRA-like) attention to management of on-site sewage systems along Puget Sound marine shorelines may be
important to controlling the effects of on-site sewage systems on loadings of nitrogen and other contaminants.

No change was made related to the target for dissolved oxygen in marine waters; we also look forward to Ecology's
No change. The target and strategies for swimming beaches are set under the simplifying assumption that enterococcus
contamination is an indication of pollution from human-caused sources that threaten the beneficial use of Puget Sound
waters for contact recreation. We recognize that correcting water quality programs at swimming beaches (and shellfish
growing areas) may confront wildlife caused problem and that those situations will require other strategies and/or a
need to confron the simplifying assumption inherent in our method of indicating human health risk at swimming
beaches and the PSP adopted target. The reference to widespread fish kills seems appropriate given that these have
occurred over some broad geographic area in a water body (i.e., a sizeable portion of Hood Canal); in documents and on-
line presentations that discuss this vital sign in more detail we will offer information about the breadth and specific
locations of problems such as fish kills. The note that the Partnership's adopted target for dissolved oxygen in marine
waters will be added to our documents and on-line presentations that discuss this vital sign in more detail. We will
work with Ecology to have more information about the marine water quality index available on-line (probably at
www.ecy.wa.gov). We recognize that the thresholds related to PAHs refer to metabolites in fish bile (not livers) and/or
to fish health effects that have been associated with PAH exposure -- the approach to assessing PAH-related thresholds
is more fully explained in other documents and on-line presentations of this vital sign.




No change -- the presentation in the Action Agenda follows the indicators and targets adopted previously by the Puget
Sound Partnership's Leadership Council. Herring, and other species on our vital signs are intended to represent other
aspects of the ecosystem; we recognize that the sellected indicators do not represent all aspects of the ecosystem and
expect that ecosystem monitoring and reporting will include information about other species.




We acknowledge the important concept conveyed in this comment and expect that depicting relationships between
actions and goals will be just the first step in understanding and adjusting actions to better aim efforts at the targets we
have adopted. The target views are an attempt to depict the contributions of the Action Agenda strategies to achieving
the targets; these target views will need to be used (i.e., in the process of adopting interim milestones for each target
and in the 2013 revision of the Action Agenda) to evaluate the Action Agenda contributions and the "likelihood of
reaching the targets based on the" adopted actions.
No change: the target for herring was adopted by the Partnership's Leadership Council in June 2011. This suggestion
will be considered for any future revision of the Partnership's target.




No change -- the lists of rivers in text and graphic do match; the targets adopted by the Puget Sound Partnerhsip's
Leadership Council recognize that some of the rivers' flows are regulated.




Change made as requested.




Results chain presentations have been revised somewhat in hopes that they can be more readable in the text. As these
new versions are being prepared in late April 2012, we do not expect that they can be reviewed prior to adoption of the
Action Agenda. We expect, however, to use the Action Agenda's depictions of results chains -- both those focused on
sub-strategies and those providing summary target views -- to allow the reader to evaluate the content of the Action
Agenda and to support PSP and partner conversations on the likelihood that targets will be achieved, potential interim
milestones for each target, and revisions needed to strategies to increase the contributions of Action Agenda strategies
and actions.
Mitigation was moved to a sub-strategy for land development and an NTA was added for Ecology to continue to
implement the mitigation that works effort.



change made




Restoration was moved to be a sub-strategy under land development; text on urban restoraiton was added.
Mitigation was moved to a sub-strategy for land development and an NTA was added for Ecology to continue to
implement the mitigation that works effort.




Text has been edited as requested.




The mitigation section has been moved to a sub-strategy of land development and has been edited to reference the
avoidance part of the mitigation sequence. Watershed based approaches to mitigation and the development of
innovative compensatory mitigation toos are key parts of Ecology's ongoing Mitigation that Works program and will
continue with that program implementaion effort.
Text of the North Central / West Sound local profile has been edited accordingly, though prioritization of strategies and
actions will continue as the LIO becomes operational.




Text of the North Central / West Sound local profile has been edited accordingly, with 13 near term actions along with
owners and milestones identified.


All NTA Comments addressed and agreed to in meeting with DFW Oil Spill Program Manager, Dan Doty on 2/16. We
significantly tightened the NRDAR language, with agreement from ECY on all too.
Ecology Spill Program funding was restored (they did not lose the 20+ staff in jeopardy at this point last year). Restoring
the 7+ FTE lost in 2008-9 is not considered viable by ECY, WDFW or xPSP Oil Spill Work Group at this time.



Ecology reductions in current budget proposals are limited to ~ 2.3 admin staff.



All NTA Comments addressed and agreed to in meeting with ECY Oil Spill Policy Lead, Jon Neel on 2/16. We significantly
tightened the NRDAR language, with agreement from DFW on all too.




C8.3 NTA 4 is an action for WDFW to establish planning efforts for coordinate, scientific collecction of ephemeral data
by local and regional entities for key species and locations at risk in oil spills to enhance response and NRDAR.
The xPSP Work Group did not ID an education priority. The xPSP Work Group agreed that Rulemaking was to be done by
separate entity (ECY). The local strategy discussions have been updated, reformatted and improved throughout the
Action Agenda. P251 Both NTAs are intended to relate directly and use the VTRA. C10.1.3 the scope has been
expanded to preparedness and response, per comment.




A brief description of this program was added to the list of key ongoing program activities.




PSP role in oil spills preparedness was added to the text of the ongoing programs section. The local strategy discussions
have been updated, reformatted and improved throughout the Action Agenda. P251 Both NTAs are intended to relate
directly and use the VTRA. C10.1.3 the scope has been expanded to preparedness and response, per comment.
PSP role in oil spills preparedness was added to the text of the ongoing programs section. The local strategy discussions
have been updated, reformatted and improved throughout the Action Agenda. P251 Both NTAs are intended to relate
directly and use the VTRA. C10.1.3 the scope has been expanded to preparedness and response, per comment.




Proposed NTAs align with some priorities ID'd by xPSP Oil Spill Work Group but are not specific or big enough to stand
alone as NTAs. Both can potentially still be pursued and funded if/when LO Nearshore funding for Oil Spill Prevention
Prepapredness and Response RFP developed.


State agencies understand this concern; but long term trends are modeled in TAPs model to produce GRPs that first
responders use even before oceanographers are consulted for near real-time projections. The Partnership will follow up
with the UW to discuss this concern further.




The NRDAR NTA was revised to include AREAS at high risk per comment.




The Partnershp appreciates this support for the oil spill NTAs.
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
interface and 40 scientists from ECB participating organizations completed an initial round of scoring. Information on
other benefits (and potential cost) was gathered from the scientists who participated in scoring and from the broader
partnership community. Information on how sub-strategies supported (or might not support) tribal treaty rights was
solicited from the tribes. The tribal information was not yet available before the April 26 Leadership Council meeting.

The results of the first round of scoring were discussed with the ECB in March. ECB members continued to express
support for the prioritization effort but had serious concerns about using the first attempt at scoring and creating a
ranked list of sub-strategies as the basis for Action Agenda prioritization. These concerns ranged from technical aspects
of the scoring and ranking process, such as how the scoring ranges were presented and whether all scorers had used the
same assumptions in scoring, to concerns that the information on human well-being and economics was not adequately
represented or considered. Key partners expressed unwillingness to support even a preliminary ranked list at this
point. In response to these concerns the Partnership has decided to delay release of the ranked list of sub-strategies to
The Partnership received extensive comment and ranking process in hopes of creating a list that partners understand
allow for additional time to refine the scoring on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
interface and 40 scientists from ECB participating organizations completed an initial round of scoring. Information on
other benefits (and potential cost) was gathered from the scientists who participated in scoring and from the broader
partnership community. Information on how sub-strategies supported (or might not support) tribal treaty rights was
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
interface and 40 scientists from ECB participating organizations completed an initial round of scoring. Information on
other benefits (and potential cost) was gathered from the scientists who participated in scoring and from the broader
partnership community. Information on how sub-strategies supported (or might not support) tribal treaty rights was
solicited from the tribes. The tribal information was not yet available before the April 26 Leadership Council meeting.

The results of the first round of scoring were discussed with the ECB in March. ECB members continued to express
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
interface and 40 scientists from ECB participating organizations completed an initial round of scoring. Information on
other benefits (and potential cost) was gathered from the scientists who participated in scoring and from the broader
partnership community. Information on how sub-strategies supported (or might not support) tribal treaty rights was
solicited from the tribes. The tribal information was not yet available before the April 26 Leadership Council meeting.

The results of the first round of scoring were discussed with the ECB in March. ECB members continued to express
support for the prioritization effort but had serious concerns about using the first attempt at scoring and creating a
ranked list of sub-strategies as the basis for Action Agenda prioritization. These concerns ranged from technical aspects
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
interface and 40 scientists from ECB participating organizations completed an initial round of scoring. Information on
other benefits (and potential cost) was gathered from the scientists who participated in scoring and from the broader
partnership community. Information on how sub-strategies supported (or might not support) tribal treaty rights was
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
interface and 40 scientists from ECB participating organizations completed an initial round of scoring. Information on
other benefits (and potential cost) was gathered from the scientists who participated in scoring and from the broader
partnership community. Information on how sub-strategies supported (or might not support) tribal treaty rights was
solicited from the tribes. The tribal information was not yet available before the April 26 Leadership Council meeting.

The results of the first round of scoring were discussed with the ECB in March. ECB members continued to express
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
interface and 40 scientists from ECB participating organizations completed an initial round of scoring. Information on
other benefits (and potential cost) was gathered from the scientists who participated in scoring and from the broader
partnership community. Information on how sub-strategies supported (or might not support) tribal treaty rights was
solicited from the tribes. The tribal information was not yet available before the April 26 Leadership Council meeting.

The results of the first round of scoring were discussed with the ECB in March. ECB members continued to express
support for the prioritization effort but had serious concerns about using the first attempt at scoring and creating a
ranked list of sub-strategies as the basis for Action Agenda prioritization. These concerns ranged from technical aspects
of the scoring and ranking process, such as how the scoring ranges were presented and whether all scorers had used the
same assumptions in scoring, to concerns that the information on human well-being and economics was not adequately
represented or considered. Key partners expressed unwillingness to support even a preliminary ranked list at this
point. In response to these concerns the Partnership has decided to delay release of the ranked list of sub-strategies to
allow for additional time to refine the scoring and ranking process in hopes of creating a list that partners understand
The will support. The Partnership is committed the proposed process to prioritize near-term actions. Summer 2012,
and Partnership received extensive comment onto finishing this process and publishing a ranked list by Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
The Partnership received extensive comment on the proposed process to prioritize near-term actions. Commenters
expressed overwhelming support for the concept of prioritization and for the Partnership’s efforts to structure a
prioritization process that would be transparent, science-based, and involve regional experts. At the same time,
commenters expressed a range of views, and questions, about the specifics of the proposed approach.

A workgroup of the Ecosystem Coordination Board was formed to discuss comments on the prioritization process and to
refine the prioritization approach. In consultation with this workgroup the Partnership Science Director worked with
members of the Science Panel who have expertise in decision support to develop a revised approach to prioritization to
the Ecosystem Coordination Board for discussion. The revised approach, which was endorsed by the ECB, involved
using a science-based effort to score individual sub-strategies based on their expected ecological impact to create a
ranked list of sub-strategies. Information about other benefits (or potential costs) associated with each sub-strategy
and implementation issues was captured as supplemental information and presented with the ranked list. It was
determined that sub-strategies would be more appropriate for prioritization.

Once a framework for prioritization that was consistent with guidance from the ECB and Science Panel was developed,
the Science Director worked with the Science Panel (as recommended by the ECB) to develop a scoring system to
evaluate the expected ecological impact of each sub-strategy. The scoring system was built out using an on-line survey
After consultation with RCO it was determined that this action is not ripe for this Action Agenda; the idea was added to
the list of future/emerging issues to consider in future Action Agenda updates.




These actions were considered carefully by PSP but determined to be not ripe for this Action Agenda. They were added
to the list of future opportunities to consider. An NTA on increasing interpretative experiences at State Parkes was
added and text changes were made to incorporate comments. Reference to Puget Sound access point maps was added
and links to the maps will be part of the on-line version of the Action Agenda.




A reference to the coastal atlas program was added and a link to the coastal atlas access maps will be provided in the
online version of the Action Agenda. After consultation with RCO it was determined that an action on requiring public
access as part of restoration or aquisition program funding is not ripe for this Action Agenda; the idea was added to the
list of future/emerging issues to consider in future Action Agenda updates. The strategy language has been edited to
clarify that access is an issue for both shorelines/beaches and the marine (open water) parts of the ecosystem.




A reference to the coastal atlas program was added and a link to the coastal atlas access maps will be provided in the
online version of the Action Agenda. The estuary target veiw has been moved.




The Partnership appreciates this support for public access to Puget Sound.
The challenge section was updated to reference that steelhead are listed. Draft NTA A9.2 NTA 2 was deleted based on
discussions with the co-managers.




The habitat strategic initiative was created, in part, to address tribal and federal concerns that habitat protection efforts
have not been sufficient.




A climate change section for salmon recovery was added. The suggested figure was not incorporated at this time as it is
not consistent with the rest of the presentations in the Action Agenda. However, this type of figure would be useful in
the Puget Sound Science Update. Better integrating climate change in the development of the three-year work plans
and funding criteria is identified in the future considerations sections.




The strategies and sub-strategies in what is now Section A6 have been revised and now incorporate several salmon
recovery specific NTAs. Implementation of the three-year work plans was added as a sub-strategy and implementation
of numerous salmon recovery plans are listed as NTAs. In addition, the strategic initiative on salmon habitat is designed
to addressed the concerns raised in the tribal white paper and by NOAA. As described in the Action Agenda, the federal
response was not available to the Partnership within the time frame to include it in the Action Agenda. It can be more
fully integrated in the future. The Partnership acknowledges the is a desire to see all the NTAs that relate to salmon in
this section of the Action Agenda. However, most of the Action Agenda has some link to salmon recovery and
presenting them again in this section was deemed too repetive in a document that many beleive is too long and
complex.




The salmon recovery section was revised and now includes the 3 year workplan implementation as NTAs.
The habitat strategic initiative was created to address tribal and federal concerns that habitat protection efforts have
not been sufficient. Ideally, state and federal actions would be aligned in the Action Agenda, however, the federal
process has remained on a different timeline from the Action Agenda and those actions were not received in time to be
incorporated. The next update to the Action Agenda will incorporate them.As part of the sub-strategy ranking process,
tribes, through their ECB representatives were rating sub-strategies on how well they help protect treaty rights. As of
late April 2012, this information was not yet available for incorporation into the Action Agenda. As the final ranking
process will be completed in summer 2012, that information can still be incorporated.




The Partnership agrees that salmon recovery is central to the recovery efforts. The salmon habitat strategic intiative
was selected, in part, to re-emphasize this connection. The salmon recovery section (now A6) was revised with new sub-
strategies and several near-term actions specifically related to implementation of the overall salmon recovery plan and
three-year work plans. The salmon recovery plan call out boxes in other sections are intended to highlight the
importance of those other actions to the overall salmon recovery effort. The Partnership did not choose to reorganize
the document so that salmon recovery appears first because of the related strategic intiative, although this type of
reorganization could be considered in the future. During the Action Agenda process, the draft actions were discussed
by the state agencies as part of their response effort. The Partnership agrees that the Action Agenda development
could be used to help develop the responses, as well as hold the complete set of agreed upon actions. As of late April
2012, the timeline of that effort and the Action Agenda has remained slightly out of sync.




Harvest, hatchery and adaptive management are now called out as a sub-strategy. In discussion with the co-managers
and NOAA Fisheries, hatchery actions were included. An H-integration action was not developed in the time available,
but should be considered again for the future. The Partnership agress that monitoring and adaptive management are
important. An NTA for the watershed chapter adaptive management plans was added. The Partnership agrees that
implementation has been an impediment to salmon recovery progress. Understanding landscape changes was included
as it is part of the overall adaptive management process.
The Partnership agrees that one important function of the Action Agenda is to serve as a guide for the expenditure of
funds for Puget Sound work, including the NEP funds. However, the Partnership does not have direct authority over
most of the NEP funding decisions. We have included in our update to the Action Agenda guidance for Puget Sound
recovery funders on how to make decisions about the allocation of resources to support the Puget Sound recovery
efforts. That guidance recommends considering how funding decisions can support implementation of strategic
initiatives as a primary consideration. We are focusing one of the strategic initiatives on habitat protection and
restoration in support of salmon recovery. The Partnership recognizes the importance of the Treaty Rights at Risk
initiative and has proposed that habitat protection and restoration in support of salmon recovery be an immediate and
high priority focus of overall Puget Sound recovery actions. The other two strategic initiatives highlight the need to
protect water quality.

The Partnership recognizes the need to ensure that regulatory programs are implemented in a coordinated and
comprehensive manner. There are several substrategies in the Action Agenda that address this need such as A1, C2,
and C9. One or more of the strategic initiatives may focus on this issue. Finally, the ECB is convening a subcommittee
on regulation. That subcommittee will likely focus on implementation of the strategic initiatives. More focus on
coordination of regulatory programs that address pollution may be addressed there.

The Partnership has attempted to make a more direct link in the current version of the Action Agenda update to the
salmon recovery plans in order to ensure that salmon recovery is fully integrated into overall Puget Sound recovery
efforts. Puget Sound Recovery Targets were set by the Leadership Council in June 2011. This version of the Action
Agenda identifies actions that are intended to move the ecosystem towards those targets. Future work will include the
identification of interim milestones so that we know if we are making progress in the short term. That work may result
in a more direct link between the Action Agenda and salmon recovery efforts. In addition, when adopting the targets,
the Leadership Council recognized that these targets will need to be adapted in the future.

The Partnership recognizes that the Puget Sound and salmon recovery are tightly linked. The strategic initiative on
habitat and salmon recovery was designed with significant discussion with the SRC chair and tribes. In addition, full
implementation of the Chinook recovery plan is called out as near-term action in terms of funding need. Other NTAs
related to implementation of the Recovery Plan have also been added. Implementation of the three year workplans
was added as a sub-strategy. Those LIOs ready to propose near-term actions have identified implementation of local
three year workplans as near-term actions. Where LIOs are not ready to do that, implementation of the three-year work
plans is still called out as key ongoing work.
The intent of Section A6 of the Action Agenda is use and reemphasize the approved regional Chinook recovery plan. The
new sub-strategies should make this clearer and the implementation of the three-year work plans is specifically called
out. In addition, other NTAs are related to implementation of the approved plan. Steelhead recovery planning steps
are included as NTAs. Finally, the strategic initiative on salmon recovery helps bolster the importance of the salmon
recovery effort, and the associated actions should be drawn from the recovery plan, as well as information developed
since then as part of the federal and state responses.




The salmon recovery section was significantly revised between the draft and final and now includes salmon recovery
specific NTAs, including funding for the overall recovery plans and lead entity capacity.




The salmon recovery section was significantly revised between the draft and final and now includes salmon recovery
specific NTAs, including funding for the overall recovery plans and lead entity capacity, as well as other aspects of
implementation of the overall salmon recovery plan.
The salmon recovery section was revised and now includes implementation of the 3 year workplans as a sub-strategy
and numerous salmon recovery plans are identifed as NTAs. Additional NTAs were added that are related to
implementation of other elements of the Chinook Recovery Plan.
This section of the action and sub-strategies were reorganized. Several near-term actions were added that address
these comment: Full funding of the Chinook Recovery Plan, implementation of individual three year workplans, and
lead entity capacity.




The salmon recovery section was significantly revised between the draft and final and now includes salmon recovery
specific NTAs, including funding for the overall recovery plans and lead entity capacity.




The text box was deleted as salmon recovery funding, as well as the broader funding needs and sources, are more fully
discussed in the Funding Strategy.
A substrategy related to harvest, hatchery and adaptive management was added to this section of the action. Harvest
programs are described and identified as an ongoing program. A near-term action for 2012 was not identified in
discussion with the co-managers and the Partnership is not chosing to lead a harvest action at this time. This request
could be revisisted in future updates.




The strategies and sub-strategies in what is now Section A6 have been revised and now incorporate several salmon
recovery specific NTAs. Implementation of the three-year work plans was added as a sub-strategy and implementation
of numerous salmon recovery plans are listed as NTAs. In addition, the strategic initiative on salmon habitat is designed
to addressed the concerns raised in the tribal white paper and by NOAA. The Partnership acknowledges the is a desire
to see all the NTAs that relate to salmon in this section of the Action Agenda. However, most of the Action Agenda has
some link to salmon recovery and presenting them again in this section was deemed too repetive in a document that
many beleive is too long and complex. The list of strategy categories was deleted from this section as it was as too broad
and repetitive.
The strategies and sub-strategies in what is now Section A6 have been revised and now incorporate several salmon
recovery specific NTAs. Implementation of the three-year work plans was added as a sub-strategy and implementation
of numerous salmon recovery plans are listed as NTAs. In addition, support for the lead entities and partners has a near-
term action that address the need to continue support for the watershed approach. The strategic initiative on salmon
habitat is designed to addressed the concerns raised in the tribal white paper and by NOAA.




Support for the Marine Managers workshop is appreciatied. Implementing the Green Shores program in San Juan
County is identified as a priority of the San Juan Action Agenda Oversight Group, and is listed as a "Tier 2" near term
action.




Kokanee are found in the freshwater of Moran State Park. The sentence has been revised to eliminate the reference to
marine waters.
The San Juan Initiative is now listed as a reference in the San Juan profile page.
The Partnership recognizes the importance of looking at costs and benefits of actions. This is also of interest to the
newly formed ECB sub-committee on funding and was added to the future opportunities list in the funding section. In
addition, the Partnership is interested in working with AWB on how to look at costs and benefits. Since the draft Action
Agenda was released in December, an ECB sub-committee on regulation was formed. AWB is participating in that work.
The Partnership supports looking at regulatory reform and has continued to recommend that this be done for a specific
issue or program area, rather than a general need. We welcome participation in identifying where to focus that work.




This is not included in the final draft as an indiviual NTA. It was originally intended to be owned by the STORM coalition
for its self-defined work. STORM is an important part of the outreach infrastructure for Puget Sound; this was intended
to reflect the need to support the STORM coalitions operations. Though no longer an NTA, we understand that STORM
has completed a strategic planning process and is continuing to identify sources of long-term support.


The Partnership agrees that completing the LIO formation process is critical. The West Sound (North Central Action
Agenda) is slated for this year. The process in the Skagit has evolved more slowly. The Partnership is actively working to
support the formation of these LIOs as part of our ongoing work, rather than call it out as a near-term action.
 Action Agenda Update strategies inform scientific priorities but Priority Science is not simply a biennial science work
plan that lists science needed to implement near-term actions in the Action Agenda Update. The Science Panel supports
the desire for a tighter link between the Action Agenda Update and the biennial science work plan. The Science Panel
organized this version of the science work plan to be a key companion to the Action Agenda Update. Priority Science for
Restoring and Protecting Puget Sound in turn uses the strategies of the Action Agenda Update to organize priority
science actions. This helps demonstrate the strategic link between implementation strategies and science needs as
determined by the Science Panel. The Science Panel also supports the legislative intent to keep the development of the
Action Agenda Update and Priority Science separate but complementary. The first is a stakeholder-based process; the
latter is intended to be a scientific analysis that may use stakeholder information to inform priorities. Monitoring
section comment: A monitoring section will be added to the final Action Agenda. RFEG comment:RFEGs are covered in
action Agenda Section A6.1 and A6.5 as their work includes on the ground restoration as well as outreach. Citizen
science comments: The monitoring steering committee is working on citizen science. This will be covered in the final
Action Agenda.
The Partnership agrees with and recognizes that there are a multitude of groups working on a broad range of recovery
activities. The intent of the LIO work highlighted in Section D2 is to bring these groups together to coordinate efforts
and create a more effective approach to clarifying and implementing local priorities. In addition, ECO-NET is intended to
support consistent messaging and outreach across Puget Sound. Section D of the Action Agenda identifies some of the
key responsibilities of the Partnership. We did not chose to include the entire performance management system in the
Action Agenda at this time. It could be included in the future. The performance work included is intended to highlight
key activities and some actions that PSP will report on with the rest of the Action Agenda. A specific NTA included at
the request of DNR is D1.2 NTA 1 to set interim milestones. A more detailed monitoring section will be added to the
final Action Agenda. The language used in D4 reflects the Partnership's role in relation to the science and monitoring
programs. The Strategic Science Plan has a longer-term horizon that two years. In addition, while the enabling the
legislation calls for a biennial science work plan, it is also requires that the plan recommend strategic improvements to
the ongoing science work in the Puget Sound (see Appendix A of Priority Science).




Section D is primarily focused on outlining the Partnership agency roles and actions that PSP is holding itself
accountable for during implementation. In the future, this section could be revised to incorporate other partner work.
For the final Action Agenda, the Lead Organizations will be added to the Management Conference description and
diagram. Lead Organization stewardship activities are mentioned in Section D.
The Partnership welcomes citizen input and supports citizen action in protection and restoration efforts. For each of
the major watersheds around Puget Sound, a three-year prioritized work plan has been developed. These work plans
often include capital projects with a citizen action focus. Partnership staff can help connect citizens to the right
watershed group. Implementation of those plans is identified in Sub-strategy A6.1. Near-term action A6.1 NTA 1 was
added to address restoration permit barriers. The commenter is referring to to Section D.4.1.1 on page 63 in the 2008
Action Agenda (Section . That specific language has been replaced and updated to be more specific and focused in
Sections A-C of the 2012 Action Agenda.




Section D is primarily focused on outlining the Partnership agency roles and actions that PSP is holding itself
accountable for during implementation. For this reason, specific partners are not called out. In the future, this section
could be revised wit

Section D is primarily focused on outlining the Partnership agency roles and actions that PSP is holding itself
accountable for during implementation. Marine Spatial Planning work is generally covered in Sections B1-3. LIOs are a
coordinating mechanism that is part of the overall Puget Sound recovery effort.
D3.1 NTA 1. The Partnership agrees that a GIS reporting system would be helpful for Canada and other partners.Initial
steps will be completed in 2012 with more work occuring in later phases of the Vital Signs work. The Partnership agrees
that strategic collaboration, including scientific coordination with Canada is important. This work is highlighted in the
Management Conference Appendix as EPA requested to see all the Management Conference structure information in
one place. In the future, Section D could be restructured to include Canadian collaboration efforts. Canadian
representation can be considered for the Science Panel, Ecosystem Coordination Board and those LIOs located on the
border. The Partnership would appreciate learning more about Canadian efforts to value ecosystem goods and services.




Comment not understood as section D3 was included in the December 2011 draft. Sub-strategy D1.2 includes updates
to the Action Agenda which is used by the Partnership and partners to advance legislation and other recommendations
that could include, but would not be limited to regulations. In addition, the actions to maintain and enhance federal,
state and local funding are covered in the funding section. The Partnership is not the only body that advances funding
and legislation, and often does this work in collaboration with partners.

The Salmon Recovery Council and Oil Spill Workgroup were added to the ongoing program activities in D1.1. The
Partnership agrees that continuation of the regional monitoring program is critical. Section D was designed to highlight
the Partnership's work. The overall funding strategy, that includes monitoring, is in a separate section. A more explicit
section on ecosystem monitoring will be added for the final Action Agenda. Pg 289 comment: The Puget Sound Starts
Here campaign is featured as a regional awareness-building effort. It was intentionally branded to accommodate broad
content, messages and actions relevant to Puget Sound recovery. Actions featured in the campaign are intended to be
1) influence-able with this type of media strategy, 2) cumulatively impacting Puget Sound and 3) relatively widespread
among the region's 4.5 million residents. The campaign intends to feature actions that span the content of the Action
Agenda and meet the above criteria. In the first two years of the campaign, work has been primarily funded by
stormwater partners; hence the stormwater focus.
The intent of the NTAs in Section D was to identify some high level actions that Partnership would hold itself
accountable for during 2012-2013. These are not the only actions that the PSP engages in. In the future, this section
could be revised to includmore specifically include other partners and more detail about all of the Partnership's work.
Partnership coordination with Canada is covered in the Management Conference Appendix, including the need to
develop a coordination agreement. For D4.1.1 comment on learning from other large ecosystem projects: this concept
will be added to the final Action Agenda. D4.1.1 comment on conceptual models: The Partnership is already doing this
work via the decision support analysis. This work includes models with substance that go beyond conceptual models.
The target relationship wording suggested will corporated into the beginning of each strategy or sub-strategy for the
final Action Agenda. The Partnership is moving toward an orientation based on outcomes. D4.2.1 comment: wording
will be clarified for the final Action Agenda. The wording in D4.2.3 was retained. PSP still believes this is important. D4
NTA 1 was deleted and is covered y A6.3 NTA 2.




Comment noted. D3.2 NTA 2 was revised. A related, added action is D1.2 NTA 1.
Section D is primarily focused on outlining the Partnership agency roles and actions that PSP is holding itself
accountable for during implementation. For this reason, specific partners are not called out. In the future, this section
could be revised with a different focus. The Northwest Straits Initiative was added to the ongoing program discussion in
Section D2.1 in relation to the LIO work. For the pgs. 286-7 comment: The Stewardship Program of the Partnership and
the work described in this section, is conducted in partnership with a range of regional networks and hundreds of local
partner organizations. Incorporating references to individual organizations and/or networks in this section would have
been too cumbersome and risk omission of some partners. Hence, we've used "partners" as an inclusive term. D.6
comment: see above response. The NWS is not called out as lead convener of the derelict fishing gear removal in
Section D as the removal actions are covered in Section B3.2 with the Foundation listed as the owner per NWS direction.
In addition, one lead convenor was not called out as WDFW plays a significant role in this effort. NWS is not called out
as the lead convenor of forage fish protection, as this is a broadly shared responsibility (see Section B5). Funding for
Action Agenda work, and its implementing partners, is an issue across the board for organizations, Near-Term Actions
and Ongoing Programs. Funding strategies are consolidated in the Funding Section of the Action Agenda. D.7.4
comment: the program described in this NTA is modeled after a successful Citizen Action Training School pilot program
funded years ago under the Puget Sound Water Quality Authority. A competitive grant will be awarded to carry out this
program; NWSC is encouraged to apply, and/or partner with the awardee.
For the final Action Agenda to be adopted in summer 2012, the Partnership will work with PSEMP to draft a more
comprehensive monitoring sub-strategy, statement or additional text for Section D that better captures the monitoring
program. In addition, Partnership staff will work with the monitoring program to ensure that the references to PSEMP
are correct, and that monitoring actions reference PSEMP.




Section D is primarily focused on outlining the Partnership agency roles and actions that PSP is holding itself
accountable for during implementation. For this reason, specific partners are not called out. In the future, this section
could be revised with a different focus. The Partnership agrees that building on existing effective programs is preferable
to creating new efforts. In spring, 2012, the Partnership conducted a Request for Information soliciting information
about existing effective behavior change programs related to Action Agenda content. The Partnership is using that
information as a basis to identify existing program opportunities, expansions, or gaps.

The intent of the LIOs to reflect the range of local options. If there are concerns that not all views are reflected, this
should be worked out with the LIO, or potentially in discussions with the ECB representative or Partnership staff. The
need to maintain funding for implementation of all programs, including monitoring and research is covered in the
Funding section of the Action Agenda. The Partnership has significant implementation roles in that effort. The FEMA
BiOp and related issues are covered in Section A5.
The intent of the Strategic Initiatives is to cut across the the strategies and sub-strategies in the Action Agenda. The
intent of the Action Agenda is to address the priority work needed, including barriers to recovery. Several near-term
actions are specifically identified to do find new and innovative solutions. The intent of the funding strategy is to
stablize and bring new funding to Puget Sound.




The local strategy call out boxes were removed. If local areas identified priority actions, those actions are included in
this section.




For sub-strategy 2.l, the Partnership acknowledges WSCCs concern. The Partnership agrees ensuring broad
representation in local processes is important, and works with local areas to help make sure this happens. D3.2 NTA 1
was revised.
The shellfish section and NTAs were revised to address comments and to more fully incorporate the Governor's shellfish
initiative. Owners for all NTAs were identified.




This edit will be made for the final Action Agenda.



The final shellfish section and NTAs were negotiated with the Department of Health and agency comments
incorporated. The information on upgrades and downgrades was summarized in a table to make it easier to
understand.
The final shellfish section and NTAs were negotiated with the Department of Ecology and agency comments were
incorporated.




The Partnership appreciates this support for some of the shellfish NTAs. C9.4 NTA 1 (now C7.3 NTA 2) was revised to
clarify.
The Partnership appreciates the support for some of the shellfish NTAs. The Shellfish section was edited significantly to
better track and align with the Governor's Shellfish Initiative. This included maintaining NTAs on best practices (C7.1
NTA 1) and environmentally responsible shellfish squaculature (C7.3 NTAs 1 - 4). Additional NTAs were added on
enhancing the publics' connection to shellfish and recreational harvest opportunities and on shellfish research.

The issue of whether additional NTAs are needed to achieve the shellfish target will be addressed as part of a discussion
of interim milestones for target achievement, which will take place after the Action Agenda is adopted.




Reference to restoration of Olympia Oysters, including the NW Straits work in this area, were added. The Partnership
did not add information on recently awarded grants.
The shellfish section has been edited and the text on downgrades/upgrades put into tables to make it easier to
understand. Proposed C9.1 NTA 1 (now C7.1 NTA 1) has been revised to refer to "best practices library" and a reference
to the Samish Bay work was added. C9.1 NTA 2 was deleted. Other NTAs were revised extensively and new NTAs were
added to ensure consistency with the Governor's Shellfish Initiative this includes adding NTAs on a pollution control
action team, shellfish interpretative programs and events, and ocean acidification.




References to Washington SeaGrant were added as requested.
The Partnership appreciates this support for some of the shellfish NTAs. The Conservation Commission was not
identified as the owner of the NTA on model program, DOH in its role supporting and working with Local Health
Jurisdictions will continue to own this NTA. C9.1 NTA 2 was revised to refer to the pollution control action team being
formed as part of the Governor's shellfish initiative.




(1) The Skagit Environmental Endowment Commission has been added into the 'References and Additional Resources'
section of the profile to support further discussions.




(1) At this time, there is not a 'Skagit LIO'. The Puget Sound Partnership is supporting discussions within the Skagit
Watershed to organize in a way that will advance the implementation of the Action Agenda. Due to this on-going
process, the profile is organized as at starting point for discussions around the content rather than a distillation of the
priorities and approach for implementing the Action Agenda in the Skagit.
(2) Additional resources and references have been added to the profile to support future discussions, including but not
limited to information around salmon recovery, water quality, water quantity, and climate change.
(3) Additional information has been added from the work of the Skagit Climate Consortium.
(1) The information included in the current Skagit Profile is a starting point for further discussion and dialogue on the
strategies and actions needed to advance recovery within the Skagit Watershed. Additional information will continue to
be added as this occurs.
(2) See response (1).
(3) Additional information has been added from the work of the Skagit Climate Consortium.
(4) Additional information will need to added as part of on-going work in the Skagit Watershed to establish a
coordinating forum, or a Local Integrating Organization (LIO).
(5) See response (4) and (1).
(6) Additional information was included in the Skagit Profile to address this concern. See also responses (4) and (1)
(7) The Puget Sound Partnership is supporting discussions within the Skagit Watershed to organize in a way that will
advance the implementation of the Action Agenda. During the time of this Action Agenda update, this organizational
work is still developing and there is currently no 'Skagit LIO'. Due to this on-going process, the profile is organized as at
starting point for discussions around the content rather than a distillation of the priorities and approach for
implementing the Action Agenda in the Skagit. Additional resources and references have been added to the profile to
support these future discussions, including but not limited to information around water quality, water quantity, and
climate change.


(1) The profile section has been renamed per your feedback that the name was confusing. It is now called, "Skagit
Watershed".
(2) The Puget Sound Partnership is supporting discussions within the Skagit Watershed to organize in a way that will
advance the implementation of the Action Agenda. During the time of this Action Agenda update, this organizational
work is still developing. Due to this on-going process, the profile is organized as at starting point for discussions around
the content rather than a distillation of the priorities and approach for implementing the Action Agenda in the Skagit.
Additional resources and references have been added to the profile to support these future discussions.
(3) See response (2)
(4) See response (2)
(5) See response (2)
(6) See response (2)
(7) See response (2). The LIOs are intended to be a sustainable forum for dialogue and collaboration. The Puget Sound
Partnership is supporting a locally-based effort to develop this structure.
The Skagit profile has been updated based on your text revisions.




(1) The Partnership recognizes that this profile is not comprehensive and is rather a starting point for further discussion
on how to organize, sequence, and prioritize strategies and actions associated with implementing the Action Agenda in
the Skagit Watershed.
(2)The Partnership would like to work with the Tribe on how to move the Skagit chapter forward, in addition to how to
move the Skagit organizaitonal structure forward in order to advance the elements within the Skagit chapter and the
Action Agenda.
(3) Additional information has been incorporated into the 'References and Additional Resources' section in order to
support the work needed for the furture. This includes the Salmon Recovery Plan, Skagit Chapter.
(4)Additional information for the Skagit Profile, including key accomplishments, strategies, and near term actions, will
be further developed as part of the role that the future LIO will play.
(5) See responses (1) and (4)
(6) General needs associated with monitoring and adaptive management have been added into the science section.
(7) Thank you for your comments. As the structure within the Skagit Watershed develops, the Partnership will support
the Tribe in conveying the key messages associated with salmon recovery and approach.
• I'm not fully clear on what is being requested here. I don't think it is a simple change to our Local Profile narrative but
more a request of tracking and accountability that is addressed in other sections of the Action Agenda....
• I believe we are removing the "notable accomplishments" box for the final version so I did not add this request. We
currently don't have another logical section in which to address the Maury Island Aquatic Reserve request. It would take
a lot of time (and space) to compile a list of projects and accomplishments and vet them with the LIO members at this
time (but a good suggestion for a project to highlight in other PSP documents).
Added a sentence on the role of the LIO Coordinator and the ERC in the local profile. This is an important sentiment
that is heard regularly as a concern from this body.



• Included suggested rewrite for D. The second request "This should also be broadened to match table for fund SWMPs
– it’s not all about the structural."may require the Caucus Group agreeing to broader language during future revisions.

• Included suggested changes in G.

• The list being habitat heavy is an issue to bring to the Caucus Group during future revisions; I did not address as a
rewrite here.

• Deleted the duplication of the "Policy alignment column". No funding sources identified in origial table from Caucus
Group.

• No specific change requested.

• Made requested changes to the stormwater section of the table and moved some bullets from problem to potential
solution columns.




Revised the language of the two priority pressures around toxics for increased clarity (with help from Scott Redman);
deleted "in the marketplace" as suggested.
Text of the South Puget Sound local profile has been edited accordingly, but prioritization of local strategies and actions
is still underway.




Text of the South Puget Sound local profile has been edited accordingly, but prioritization of local strategies and actions
is still underway.
Text of the South Puget Sound local profile has been edited accordingly with interim ecosystem restoration priorities
included.




explained in the new opening for the Whidbey Aciton Area



Thank you, completed.




Thank you, at this time these comments will be forwarded to the local area for consideration when they revise the local
profile. The profile will be completed within the next year or so.




Thank you, completed
2/15: Comment noted re: C.2.2 NTA 1. Re: whether to add new NTA re: state legislation that helps ensure long-term
stable funding for SW, while I agree this is needed and a good idea, it hasn't been discussed sufficiently to add it in now.
Needs much more discussion, thought. No changes made.
2/29: Re: Placement of redevelopment with existing development, no change. While it is true that permits refer to new
development and REdevelopment, redevelopment does refer to existing development. The Action Agenda addresses
the root causes of harm to PS, not necessarily the tools (permits). Better to align with the root causes, not the tools, as
tools vary and do change.
Re: LID, we completely agree. There is currently language stressing LID and protection of native vegetation.
Re: permit coverage, we agree. The current language calls for evaluation of additional jurisdictions to cover.
Re: redevelopment, we agree. Current language calls for redevelopment policies to be fully implemented - add "and
permits" to re-emphasize the permits.




2/15: We disagree that new development causes no harms to Puget Sound. While new development practices have
improved significantly, science shows that as native forests are replaced by new development, degradation of
freshwater stream resources occur. Conventional development practices have proven inadequate in fully mitigating for
the full range of impacts to freshwater systems. Low impact development shows great promise at greatly improving
protection, and that's why our region is transitioning to this new set of principles and practices. However, many
developments still being built today utilize outdated stormwater controls (pre-2001 Ecology manual). This NTA simply
calls for an assessment of the projected implications and impacts of current state laws on aquatic resources and
beneficial uses. It does not call for any change to state RCWs. No changes made to NTAs.




2/15: No changes made to NTAs.
C.2.1 - Mapping: This sub-strategy, and the accompanying NTA, refers to new consistent definitions, protocols and
methodology. This is outside the new (2013) permits and is intended to, over time, make more consistent mapping of
the regions municipal SW system. This is the first step in a multi-year effort. No new requirements will be expected of
permittees. No change made.
C.2.2 - NPDES Permits: This sub-strategy discusses general objectives for the permits (and other objectives to prevent
harm from new development). It is completely understood that there will continue to be a separate, public process for
developing NPDES permits, administered by Ecology. No change made.

RE: the NTA re: evaluating treatment standards, this is the intent of this NTA - to determine for which land uses and for
which pollutants additional treatment (above TSS removal) may be needed to meet our objectives for PS recovery. All
this is to be determined, once studied by Ecology, in cooperation with interested parties. No change made.

RE: the NTA on legacy pollutants, this refers to the cleaning of SW systems to remove pollutants found in the systems.
This doesn't differentiate between pollutants - outlawed or allowed. If pollutants are being used in a municipality, that
should be considered an enforcement issue and should be addressed in source control and illicit discharges. No changes
2/15: Only one comment on NTA; will address other comments later.
Re: C.2.2 NTAs comment, no changes made. Increasing permit fees did not come up during IDT meetings, nor at public
workshops.
3/5: Added new line under challenges re: SW affecting marine sediments. Also added scouring stream beds to bullet
under flows.
No change re: permit be strengthened over time and state laws protecting WQ - we agree and text states that permits
should be strenthend, improved with each cycle.
No change re: manual itself not fully protecting WQ - we agree - manual is just one component of permits, which, while
helpful, are in themselves only one component of fully protecting WQ. It's the whole package, well executed, that's
needed.




C.2.2 NTA 1 - Good comment, but it's very difficult to set a target for increased financial assistance. No recommendation
provided. No changes made.
C.2.2 NTA 2 - The deliverable, or perf measure, should be the evaluation. Adding in "draft treatment criteria" pre-judges
the outcome. Perhaps no change to current treatment standards is warranted. No changes made.
C.2.2 NTA 3 - Made some edits to text. Sept 2012 is the start of the assistance, not documented reduced impacts. Made
several changes: Initiate assistance by Sep 2012; Identify sites by Dec 2012; Document reduced impacts at sites by Mar
2014 and at conclusion of projects.




Comments noted. No changes made.
C.2.1 NTA 2 - Mapping: 2/14-16, Negotiated with Kathleen Emmet (Ecology) and Doug Navetski (King Co) so that King Co
would be owner for this and Ecology would be 2nd owner. Need to highlight clearly in Action Agenda that this action is
contingent on funding. WSDOT interested in participating, but not leading or co-leading (Ken Stone).
C.2.2 NTA 1 - Added issuance of permit to this NTA
C.2.2 NTA 2 - No changes made. This is not currently being done - TMDLs refer to additional actions needed; this NTA
refers to the potential need for additional treatment for all projects, not just those discharging to an impaired
waterbody.
C.2.3 NTA 1: Will revise text on this to reflect that lead should use key existing, available information.
C.2.3 NTA 2 & 3: No changes made - the NTA re: the SWG will be added back in.
C.2.5 NTA 1: Agreed that Ecology is the best lead for this. Made change. Not sufficient argument for keeping PSP as 2nd
owner, so deleted PSP.
C.2.4 LNTA 3: Will work with Scott W to revise this LNTA. No changes to text made as of 2/17.
C.2.6 LNTA 1: Will work with Scott W to revise this LNTA. No changes to text made as of 2/17.




2/15: re: C.2.2 NTA, whether to add new NTA re: state legislation that helps ensure long-term stable funding for SW,
while I agree this is needed and a good idea, it hasn't been discussed sufficiently to add it in now. Needs much more
discussion, thought. No changes made.
2/29: Including a goal re: full coverage of PS under the permit is presumptuous - maybe using the permit everywhere is
not the best option. No change. The real goal is ensuring adequate SW mgmt everywhere - the permit could be the
answer but it doesn't necessarily need to be. State law could be utilized; incentives also.
Also, all ongoing programs will be reviewed and beefed up.
2/15: No changes made to NTAs.
Next, re: other text:
1. Comments noted. Re: the need to highlight more the use of incentives, we are open to this; however, no specific
suggestions are offered. Re: restoring freshwater streams to restore "fair" streams to "good" conditions, we
acknowledge that numerous actions, including but not limited to retrofits and riparian habitat restoration, will be
needed to restore these streams. We believe these and other strategies/actions will be identified if this NTA is
implemented. We note support for certain NTAs.
2. Re: C.2.1, comments on this section are noted. Review this section so that it's clear that actions undertaken in
Strategy A are needed in conjunction with these sub-strategies and actions.
3. Re: C.2.1 NTA 1 and C.2.3 NTA 2, King County is assigned to work with other agencies that populate the PS Stream
Benthos, and the strategies and actions will be developed - they are not defined yet. No changes made.
4. RE: C. 2.1 NTA 2, our office is working with Ecology and King County to determine the most appropriate lead.
5. RE: C.2.2 sub-strategy, this is a sub-strategy that just describes the objective. Specifics about how this would take
place are described in the NTAs, once there is an NTA related to this. For this Action Agenda, the focus of the work
outside NPDES muni permitted areas is on restoring high-priority shellfish areas degraded by stormwater runoff. No
changes made.
6. RE: C.2.2 sub-strategy, NPDES permits, review this section to ensure comments are addressed. 2/29: No change -
permits will be reviewed and improved over time after careful examination of many factors, including but not limited to
TMDL waste load allocations.
7. Re: C.2.2 NTA 2, we agree that the timing of this NTA will mean it won't be added to the Ecology manual until the
next permit cycle. However, the current permits were released for public review in Nov 2011, and are scheduled for
reissuance by July 2012 - it is unreasonable to expect that this action will be completed in time for the current round of
permits. No changes made.
8. RE: C.2.2 NTA3, we don't know where these shellfish growing areas will be, nor how large they will be. First they must
be identified, then that can be determined. It is more important that the shellfish growing areas be important (socially,
economically and culturally), not necessarily of a given size. No changes made.
9. Re: C.2.2 NTA 4, we agree - addressing the vesting issue is important.
10. Re: C.2.2 LNTA 5, we agree - a performance measure should be pulled from the action and listed. Bruce started by
asking Scott W and Martha about this. Same with C.2.4 LNTA 3.
11. Re: C.2.4 TMDLs, review language and consider making suggested changes. 2/29: Added recommended language re:
monitoring in TMDLs.
2/15: No comments made on NTAs.
Next: Re: other text, we agree that the "excellent" streams will be located in rural areas. Stormwater managers are
increasingly interested in protecting the "last best remaining habitat," and managing at the broad watershed scale. This
NTA addresses this theme. Strategies and actions to protect these areas will require concerted action in areas located
outside urban stormwater managed areas (outside permitted areas). No changes made.
2/15: No changes made to NTAs. It is understood that additional resources are required for King County to implement
the two NTAs where the County is designated as lead (C.2.1 NTA 1 and C.2.3 NTA 2). Recommend highlighting this in the
text (for all NTAs where additional resources are required for imlementation). Talked to Jim Simmonds about this 2/15
at SWG meeting and he's fine, understands this action is contingent on KC getting new funding. Doug Navetski on 2/16
said the county is willing to be named lead for NTA on system mapping.

Re: C.2.5 NTA 1, we agree that it's important to support community colleges (and really all colleges and universities)
that provide these types of classes and this type of education. However, at this point, given the importance of providing
highly focused education and training to those responsible to implementing stormwater mangement, and in particular
LID, we feel it's most important to focus on this type of training. This suggestion is good, and should be considered in
the future. No changes made.

Re: the discussion of SW on page 182, we agree - SW is managed through multiple tools. Review this section and make
needed changes. 2/29: Growth mgmt planning already there; added shoreline mgmt planning.

Re: the discussion of LID on page 184, which we believe this comment refers to (no page referenced): There are two
mentions of maintenance in this paragraph, which we believe stresses the need for proper maintenance of LID facilities.
2/15: C.2.2 NTA 4 calls for an assessment of current law and policy to ensure its effective and not inconsistent with PS
recovery goals. It is reasonable to undertake this action. No changes made.
Support for addressing existing development noted. No changes made.




2/15: Comments noted. Recommend passing along to Alana, Perf Mgmt Team. No changes made.
2/15: No changes made - funding needs is very prominently described.
RE: adequate financial support for stormwater management, and in particular local stormwater programs, we couldn't
agree more. That is why the need for additional resources is highlighted in C.2. In particular, as one example, C.2.2 NTA
1 calls for additional financial resources to NPDES municipal permitees. No changes made.




2/15: Comment noted. No changes made.




2/15: No changes made to NTAs.
Support for NTA C.2.2 noted.
Support for NTA C.2.3 noted. Additional funding for retrofits is required for meaningful new effort.
Support for NTA C.2.5 noted. LID requirements are already added to the draft Municipal NPDES permits - this NTA is
merely ensuring that given these new requirements local staff and the private sector have sufficient skills and training to
implement the new LID requirements effectively.
2/15: No comments made on NTAs.
Next: C.2.2 - review language and consider adding language re: funding needs and development, if needed.
2/29: No change - there is already a separate section on funding. Also, the call to evaluate other jurisdictions for
coverage under the permit could well include evaluation of cities <10,000 in population. No change.




2/15: No changes made to NTAs.
1. Unclear which part of C.2.2 Stormwater NPDES permits they're referring to, so no change made.
2. Re: NTA on the PSRC and SW retrofits, it's still being discussed whether PSRC is appropriate lead for this project. (MT:
Note Seattle questioning this.) Changes to this NTA may be made.
Support for WA SW Center is noted. No change needed.

2/29: Now it's clear that #1 comment above refers to C.2.2 NTA 2. Answer: Which pollutants will be determined only
after a careful, deliberate evaluation is done.




2/16: No comments on NTAs. Will review comments again later in terms of other text.
3/5: No change re: WS characterization - this is just a tool to help improve local decision making - other key factors, like
tribal rights, must also be taken into account.
No other changes: re: emerging contaminants - we agree. C1 focuses more on control of toxics, including emerging
contaminants, while SW focuses on treatment of those contaminants once in the SW stream. Re: education of
homeowner associations, no change and we agree - pass this comment on to Dave Ward as an FYI re: future possible
public education.
2/15: No comments on NTAs. Will review comments when reviewing other text.
2/27: Made suggested change.


2/15: No comments made on NTAs.
2/29: No change - Ag covered elsewhere.


2/15: Comment noted. No changes made.




Changed bullet for WRIA 17 within the Instream Flow Rule Packaged LNTA to read the following: "Implement WRIA 17
Instream Flow and Water Management Rule". While not identified as a Packaged LNTA, sustaining and improving
capaciy for local organizations, including support for the EJWC for WRIA 17, is inherently a part of the Strait ERN Local
Recovery Capacity Strategic Priority, the details of which need to be developed at a future Strait ERN Speaker Forum on
the topic.
Revised last paragraph on page 400 to better explain the relationship among Strait ERN Strategic Priorities and specific
Priority Actions and the Packaged Local Near Term Acitions. ID#6 - See the most current version of Appendix A2 from
the Strait ERN 2011-13 Internal Work Plan for more details ID#18 - See the most current version of the North Olympic
Peninsula Lead Entity for Salmon Recovery (NOPLE) and the Hood Canal Coordinating Council's 3-Year Work Plans
available from this website: http://www.psp.wa.gov/SR_threeyearworkplan.php Yes, the NOPLE3-Year Work Plan does
include the three specific projects mentioned within the comment. ELJ is an acronym for Engineered Log Jams. ID#15 -
The specific Priority Actions listed as part of the "Oil Spill Preparedness, Prevention, and Response" Packaged LNTA have
been revised by the Strait ERN since the 2012 Draft Action Agenda was released for comment. That revision includes a
more detailed description of each of the specific Priority Actions.




Assignment of "owners" and performance measures can be found in the table of "Packaged Priority NTAs" in the Strait
local profile. In public comments, the Strait ERN recommended adding protection of groundfish habitat to one of the
strategic initatives. However, no priority local near-term action specific to rockfish was identified through the local
process. Please see response to comment #440 for a response to that request. For designation of Wild & Scenic Rivers,
please refer to response to comment #386.
All of the substantive text within these comments will be included in the final version of the Strait Action Area Profile, as
agreed to and requested by the Strait ERN's Oil Spil Task Force, of which, the Makah Tribe is an active member and
supporter.




Your participation in the Strait ERN is appreciated.
PSP is interested in supporting the role of local integrating organizations like the Strait ERN in identifying local priorities.
This project was identified locally by a majority of voting participants. In this case, PSP defers to the locally-derived
decision.
The profile was revised to reflect these suggestions.




Thank you -- comment noted. Significant work was undertaken in consultation with the ECB to clarify and define the
strategic initiatives that are moving forward.
The Partnership apprecites this support for the strategic initatives. After considering comments the Partnership
proposes the following initiatives for adoption by the Leadership Council: prevention of pollution from urban runoff;
protection and restoration of habitat in support of salmon recovery; and restoration of shellfish beds.

In March, the Partnership brought a draft refined set of strategic initiatives and an outline of initiative content to the
Ecosystem Coordination Board for discussion. There was continued support for the three initiatives, but some concern
that the content of the initiatives would require additional review and vetting. Some ECB members also offered specific
comments on the content of the initiatives. Some other ECB members provided written comments on the content of
strategic initiatives after the meeting. In early April, in response to ECB requests for additional review, the Partnership
provided a revised draft of strategic initiative content. A number of ECB members expressed serious concerns over
potential gaps or other flaws in the content and urged the Partnership to take additional time to work with the ECB. In
response to these comments, the Partnership is delaying action on the content of the strategic initiatives to allow more
time to work with Partners to refine the content of the strategic initiatives. It will consider these comments further as
part of that effort.




NTA was revised per a number of comments to reflect lead role of landscapers association(s) in developing the
accreditation program
Added a description of the early 2015 deadline related to copper in brake materials.

Deadlines are speciified for performance measures.

No change was made re: OEHST -- will convey comment to Ecology WQ program and TCP

No change to C1.5 for local programs -- see C1.4 about local source contrrol (construed as technical assistance rather
than enforcement)

Introduction was changed to better discuss COC and emerging chemicals

No change to statement about endocrine disrupting chemicals: general reference to threshold levels is simpler
language and more consistent with the complexity of the thresholds encompassed by this target.

No change in C1.2 to address comment about phosphates in fertilizer. C1.2 is limited to alternatives to toxic chemicals.

No changes were made to to ongoing programs and/or future opportunities related to DOH comments on p. 177 and
C1.1 NTA3 (p. 169). These concepts will be addressed as PSEMP's toxics monitoring work group identifies monitoring
priorities.
Noted




Introduction was revised as suggested.

NTAs were revised as suggested except (1) C1.1 NTAs 4 & 5 were not combined but were revised per others comments
and (2) local source control NTA was added to C1.4 rather than creating C1.6.
Added emerging contaminants NTA as suggested.

Logic chains (strategy and substrategy level results chains) will be developed for C1

NTAs revised to more clearly identify the leads.

Title of C1 changed as suggested (and then further changed as we included sub-strategies focused on contaminants
other than toxic chemicals)

Discuss of TSCA was modified to reflect the comment and comments from Ecology

C1.1 NTA2 -- detail was not added; NTA tracking will be conducted as a sufficient level of detail to respond to this
comment

C1.1 NTA3 was amended as suggested.

C1.1 NTAs 4 & 5 were revised to clarify

C1.1 NTA6 was DROPPED

New C1.1. NTA (new 6) was added re: transboundary toxic chemical controls. Per discussion with Ecology (and EPA? --
i.e., did Gerry discuss this with Dennis as planned?), EPA was identified as the lead.

Intro to C1.2 changed to clarify statewide or PS specific perfomance metrics for ongoing programs

C1.2 NTA1 was split into two as recommended; introduction includes information about roofing matriala actions as a
next step from the PSTLA

C1.4 NTA2 -- title was added as suggested

No new NTA in C1.4 related to pharmaceuticals and personal care products. This concept was worked into a new NTA in
C1.1 NTAs related to copper and pesticides have been revised to align with WSDA interests and approaches.

C1.4 Landscaper accreditation NTA has been revised to show key role for business associations
No revisions to C1.1 NTA1 and C1.1 NTA3. Comments on CAPs will be shared with Ecology for their consideration as
they develop actions to include in the CAP. Comments on water quality standards will be shared with Ecology for their
consideration in possible revisions to water quality standards and sediment management standards related to new
information about fish and shellfish consumption rates.

C1.1 NTAs 4 and 5 are revised. Comments on copper and other water quality parameters related to agricultural runoff
will be shared with WSDA and Ecology for their consideration of possible next steps related to copper in agricultural
runoff.

C1.2 NTA1 revised as suggested to include “or ways to use materials that minimize releases of toxic materials to
receiving waters.”

C1.5 NTA 1 performance metric was not revised -- this metric seems appropriate given that one goal of the inspections
effort is to reduce the amount & improve the quality of wastewater discharged from the inspected facilities to
municipal sewage systems or to the Puget Sound environment




C1.4 Landscaper accreditation NTA has been revised to show key role for business associations
This NTA was changed per Ecology's comments and now only refers to revisions to Sediment Management Standards.
Change made.
No change




C1.1 NTA3 -- no change; NTA is simply to develop the information so standards can be updated through Ecology
processess

C1.1 NTAs 4 and 5-- were revised to (1) include review of copper used in agriculture and (2) survey about all pesticides in
non-agricultural use.

C1.1 NTA4 has been dropped -- this comment will be shared with PSEMP's toxics monitoring work group

C1.2 NTA1 -- noted and comment will be shared with Ecology

C1.3 -- no change was made to add a discussion of incinerator emissions of dioxin to the Action Agenda. Ecology's 2011
report on primary sources of toxic chemicals released to the Puget Sound environment notes (on p. 126): "There are no
medical or municipal waste incinerators currently operating in the Study Area (Yake et al., 1998; Gary Palcisko, Ecology
Air Quality Program, written communication)."

C1.4 NTA1 -- was revised per comments from multiple parties; scope of landscaping practices & benefits was expanded
as suggested.
No new NTA. Specfiic actions called out as NTAs and key ongoing program activities represent followup steps to from
toxic loading study. Introduction to C1 will be revised to clarify this point.




NTA was dropped.

Will check other references to loading and will consider adding the "and affecting aquatic life"
No change -- note that C1.4 includes commitment to local source control (characterized as a form of technical assistance
rather than enforcement)




No changes were made to respond to this comment -- the Partnership disagrees with the characterization of this action
(and other actions) as advocating and beyond the jurisdiction of the Action Agenda




C1.1 NTA6 will be dropped. This activity might be discussed as a key ongoing program activities (or elsewhere in
introduction to C1.1 and will be addressed in D.4 to ensure alignment with PSEMP and the stormwater monitoring work
group
The NTA was revised to reflect the key role for the assocations.




The Partnership disagrees that this is a kitchen sink approach. The Partnership's role is identify the work needed and
prioritize it.




No change to C1.1 NTAs -- these NTAs represent specific (many already planned) activities to follow on from the PSTLA.

Chemical policy reform at the state level was not added as an NTA. A number of Washingtion state actions related to
improved chemical policy are discussed in the introduction to C1, C1.1, and C1.2 and in the section on emerging issues
and future opportunities (including the state's children safe products act and private sector responsibility for product
stewardship)

The suggested wastewater re-organization was not made. Information was added to the introduction to C1 to clearly
explain how C1 and C6 cover industrial wastewater

Partnership will consider adding something like C1.5 across all other A, B, and C strategies in future revisions of the
Action Agenda -- this type of revision was not feasible in the early 2012 revisions
Mussel watch comment sent to PSEMP toxic chemical work group

A new NTA has been added related to "emerging contaminants." This comment will be forwarded to Ecology & PSP for
consideration in implementing this NTA

Comment on water quality standards protective of tribal members' health sent to Ecology for consideration in revising
WQS.




Sewage sludge has not yet been identified as a high priority pressure to address and a separte section to address this
concern was not developed. However, it was added as a future consideration in Section C1 for the final Action Agenda.
Should this issue be included in the future, such a section would be developed collaboratively as that is the charge of
the Partnership.




Point source pollution is addressed in C6 (and somewhat in C1) -- this Action Agenda revision focuses on priority
controls suggested by the PS Toxics Assessment. Future revisions may look at stronger toxics controls for point sources
based on this and others comments (e.g., mixing zones for PBTs, stronger pretreatment standards)
 No changes were made: this Action Agenda revision focuses on priority controls suggested by the PS Toxics
Assessment. Future revisions may look at stronger toxics controls for point sources based on this and others comments
(e.g., mixing zones for PBTs, stronger pretreatment standards) and additional tools such as product labeling




C1.1 NTA6 will be dropped. This activity might be discussed as a key ongoing program activities (or elsewhere in
introduction to C1.1 and will be addressed in D.4 to ensure alignment with PSEMP and the stormwater monitoring work
group

NTAs were revised as suggested. Next steps based on the revised NTAs were included in future opportunities portion of
C1.
After consultation with Commerce, Ecology and Health the Partnership has deleted C7 except for C7.1 NTA 2 (now C5.1
NTA 4) on centralized treatment outside of UGAs. Commerce has agreed to lead this action.




Text was edited to incorporate comments and additional comments on the GMAP goal will be considered in future
GMAP revisions.
The Partnership agrees that reclaimed water is an important strategy; Ecology is leading the reclaimed water rule and
will resume rulemaking by 2013. The Partnership did not choose to take on additional responsibilities related to
reclaimed water at this time. Did we make these text edits?
The final wastewater section was negotiated with DOH and Agency comments were incorporated. Outfalls are
addressed in B3.1 NTA 2.
The final wastewater section was negotiated with Ecology and Agency comments were incorporated. The discussion of
vessel and boat pollution was moved to C1.5.




The recovery target for Puget Sound is to inventory all OSS and fix all failures and be current with inspections at 95% in
marine recovery areas and other designated ares by 2020. The idea of mapping locations, types and maintenance
requirements is a topic that has been addressed by the HCCC in Hood Canal; lessons learned from that work will be
considered in future Action Agenda updates. The numbers of WWTP discharges were a surprising point of debate
during development of the draft Action Agenda and again during the formal comment period. The numbers in the
Action Agenda were provided and checked by Ecology.

The Partnership discussed the issue with Ecology and was not able to develop additional strategies and actions for
industrial facilities at this time; this will be an issue for improvement in future Action Agenda development. Many of the
stand-alone sections referenced (eg mitigation that works) have been combined into other sections to simplify the
Action Agenda. Similarly, the Partnership was not able to reach agreement to develop an NTA on pretreatment at this
time; concern over pretreatment requirements has been described in the text of C6.1.

A new NTA on CSOs was added (see C6.2 NTA 1). The geographic descriptor (urban and urbanizing) was removed from
C6.3 (this was removed in the NTA table; text in narrative section of the Action Agenda will be edited to conform) and
language on water quality cleanup plans was added. The issue of emerging chemicals is addressed in the emerging
issues and future opportunities list, including its relevance to reclaimed water programs.

An NTA on the cruise ship MOU in progress was not added, although the Partnership has been in contact with the Port
of Seattle on this issue.
Technical corrections and edits to text on the OSS target and average costs were made to text in consultation with DOH.
Development of a funding mechanism for local OSS programs is described in C5.3 NTA 3. In consultation with Ecology,
the Partnership was not able to reach agreement to develop an NTA on pretreatment at this time; concern over
pretreatment requirements has been described in the text of C6.1., C6.1 NTA 1 was deleted based on Ecology
comments.




The cruise ship MOU as not added as an NTA, although the Partnership has been in contact with the Port of Seattle
about this concern.




Priority-setting is being addressed by an ongoing process that will be complete in summer 2012. The relative
contribution of wastewater from OSS or advanced WWTPs varies greatly in Puget Sound. In rural areas, OSS systems are
the accepted and conventional treatment technology, and these systems must be maintained. In large metropolitan
areas such as King County, advanced WWTPs are necessary to deal with the density and complexity of urban
communities. These systems are regulated under a federal permit administered by the Washington Department of
Ecology.
The distinction is noted between enterococcus and fecal coliform bacteria in the swimming beaches section and the
shellfish section, respectfully. There are multiple NTAs to address the need to create stable OSS funding for
homeowners and Local Health Jurisdictions, they are addressed in C5.3 "Improve and expand funding for small on-site
sewage systems and local OSS programs." C7 has been deleted except for C7.1 NTA 2 (now C5.1 NTA 4) on centralized
treatment outside of UGAs. Commerce has agreed to lead this action. Text edits have been made throughout.




The importance of addressing pollution from CSOs and SSOs is recognized. Part of the debate revolves around the
relative benefit for large expenditures of money to deal with this source, compared to other pollution sources. The
debate is being staged in important urban areas like King County. An NTA on CSOs was added (C8.2 NTA 1) to get at this
issue.




Multiple NTAs address support for local OSS programs. C5.1 NTA 1 addresses work with local health jurisdictions to
evaluate the effectiveness of the OSS rule and outline any potential changes; C5.1 NTA 2 addresses development of OSS
best practices; and C5.3 NTA 2 addresses a regional OSS program funding source.




After further discussions with Parks, it was decided not to add NTAs on septic/sewer upgrades at State Parks at this
time.
The recovery target for Puget Sound is to inventory all OSS and fix all failures and be current with inspections at 95% in
marine recovery areas and other designated areas by 2020. The Partnership agrees the that consideration of existing
self-reporting systems should be part of the evaluation of OSS best practices (to determine if it is a "best practice" or
not).

DOH tracks a number of performance measures for the LOSS rule including: issue permits for LOSS previously permitted
by Ecology as the permits expire; and issue permits for LOSS previously permitted by local health jurisdictions as the
permits transfer to DOH.

The Partnership reviewed the issue of industrial facilities with Ecology and was not able to develop additional strategies
and actions for industrial facilities at this time; this will be an issue for improvement in future Action Agenda
development. Similarly, after discussions with Ecology, the Partnership was not able to develop an NTA on
pretreatment at this time; concern over pretreatment requirements has been described in the text of C6.1

A new NTA on CSOs was added (see C6.2 NTA 1). The issue of emerging chemicals is addressed in the emerging issues
and future opportunities list, including its relevance to reclaimed water programs. We note that LOTT in south sound is
launching a comprehensive reclaimed water monitoring study which will be completed in 2016. The scoping process for
the study will be launched before the end of 2012.

The Partnership has move the discussion of vessel pollution to C1.




Local strategies and profiles were updated based on new information provided by the local areas.




C5.3 NTA 1 addresses funding for a unified, self-sustaining, low-interest loan program to help OSS owners repair and
replace systems.


(1) Adjustments have been made to update the content to be more consistent with the regional strategies. There
remain some differences due to changes in the regional document made after the WRIA 1 group already started
working on their strategies.
(2) The WRIA 1 group established general connections to the recovery targets and will continue to vet and link local
priorities with regional targets.
(3) The entire Joint WRIA 1 Policy Board is the LIO. The LIO was incorporated into this pre-existing structure and on-
going work is occurring to further develop the work group structure to most appropriately .make recommendations to
the policy groups. .
(1) These projects are great accomplishments. The LIO chose, at this time, to not highlight any one specific notable
accomplishment since there was not time to run an appropriate process.
(2) Additional information was included on the Cherry Point Aquatic Reserve in the profile narrative, strategy, and
target sections.
(3) The draft Action Agenda was missing information prepared by the Whatcom LIO on threats. This information has
been incorporated in the final Action Agenda and has also continued to be refined by the LIO group.
(4) Information was included on the POB connection to restoration opportunities within the strategy spreadsheet
(which can be found as a link to the Whatcom Profile)
(5) Additional information was included on the refineries. The LIO will continue to work on refining the strategies and
near term actions and has received this comment.




(1) These projects are great accomplishments. The LIO chose, at this time, to not highlight any one specific notable
accomplishment since there was not time to run an appropriate process.
(2) Additional information was included on the Cherry Point Aquatic Reserve in the profile narrative, strategy, and
target sections.
(3) The draft Action Agenda was missing information prepared by the Whatcom LIO on threats. This information has
been incorporated in the final Action Agenda and has also continued to be refined by the LIO group.
(4) Information was included on the POB connection to restoration opportunities within the strategy spreadsheet
(which can be found as a link to the Whatcom Profile)
(5) Additional information was included on the refineries. The LIO will continue to work on refining the strategies and
near term actions and has received this comment.



(1) The profile narrative is intended as a broader overview. Information has been included about the refineries in both
this narrative and in the pressures (or threats) section of the profile. The LIO will continue to work to refine the
information around strategies and actions, including evaluating key threats.
(2) The regional element of the Action Agenda includes information around oil spills and vessel traffic. Additional
information at the local scale will continue to be fleshed out via the LIO on the unique threats, strategies, and near term
actions within Whatcom.
(1) The draft Action Agenda was missing information prepared by the Whatcom LIO on threats. This information has
been incorporated in the final Action Agenda and has also continued to be refined by the LIO group.
(2) Climate change issues have been incorporated into the regional part of the Action Agenda. The LIO will continue to
refine the Whatcom profile, including strategies and actions. This comment on climate change has been received by the
LIO, and PSP is prepared to support discussion around climate change concerns.
(3) The LIO is continuing to refine their profile. Including information around timelines, resource needs, and goals is part
of the LIO work plan for 2012.
(4) Strategies and actions used for the local action area are the strategies and actions that are in current work plans of
various groups. Further work to refine this information is part of the 2012 LIO work plan.
(5) See above response (3) and (4) on the status and work plan.
(6) The Whatcom LIO has received this comment. See above response (3) and (4) on the status and work plan.
(7) Information around groundwater protection is currently incorporated into the following strategies: Instream Flows
Negotiation, Lower Nooksack Strategy, Recovery Plan Implementation, and Farm community coordination.
(8) The LIO in Whatcom is continuing to refine and develop the strategies and actions within the profile. The LIO has
received this comment.
(9) See above response (8).
(10) See above response (8). The LIO is continuing to work on the science and monitoring needs. The regional element
of the Action Agenda does include monitoring but specific priorities locally need to be identified within the LIO.
(11) See above response (10).
(12) The LIO work plan for 2012 includes further developing the work group function and approach, including public

				
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