Puget Sound No Discharge Zone for Vessel Sewage. Northwest Straits Commission, January 29, 2016

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1 Puget Sound No Discharge Zone for Vessel Sewage Northwest Straits Commission, January 29, 2016

2 What is a No Discharge Zone (NDZ)? Designated area where both treated and untreated sewage from vessels cannot be discharged States with NDZs Provides states with the ability to regulate discharges Widespread use of NDZs; over 90 established in 26 states

3 Current Law vs NDZ Current Law 3mi from shore can discharge untreated, if toilet on board, must use USCG certified MSD to discharge within 3 mi Authority CWA, USCG enforcement authority NDZ No discharges treated or untreated in NDZ area (sewage only), holding capacity necessary Authority CWA, state petitioned, local enforcement authority

4 No Discharge Zone Project led by Ecology Evaluation of feasibility of establishing a NDZ in all or parts of Puget Sound NEP grant funding/wadoh, PSP Action Agenda, Washington Shellfish Initiative Ten reports, including: Vessel populations and sewage management, Puget Sound conditions and modeling, pumpouts, costs/benefit, implementation and a draft petition Extensive stakeholder outreach, evaluation and reports not required and not done by other states

5 Existing: treated sewage anywhere, untreated beyond 3 miles do not typically meet WQ standards; study of type II treatment avg >2 million fecal, maintenance concerns Sewage discharges treated or untreated can cause pollution and risk to sensitive water bodies and shellfish Vessels are moving outfalls Why Preventable pollution source

6 Which States have NDZs? States with No-Discharge Zones established as of August 1, NDZs in 26 States EPA Region 10 only EPA region without a NDZ 8/1/14 6

7 Puget Sound Water Quality Unique hydrology Water quality standards 303d listed bodies

8 Vessels Are One of Many Sources

9 Marine Sanitation Devices MSD never designed to meet our WQ Standards (fecal and some solids criteria only) Type I. (ex. Electro Scan) * Maceration and disinfection * Can perform well for disinfection, but lacks ability to treat organics, solids, toxics and nutrients Type II. * Vessels >65 feet * Typically biological and disinfection; some advanced * Even advanced systems have difficulty limiting ammonia, metals

10 Summary of Recreational Numbers Estimated number : 153,000 recreational vessels in Puget Sound~ 47,000 boats over 21 feet (based on registration data) 700 to 1000 liveaboards. A subset of registered vessels and moorages Vast majority have Type III MSDs An estimated 95% of recreational vessels can comply

11 What do we know about recreational pumpout facilities? Approximately 99 Public pumpout facilities and 13 pumpout boats in Puget Sound More are located in areas of high boat density, generally good coverage throughout the Sound EPA Guidance: 300 to 600 boats per pumpout based on peak occupancy There are (moorage vs registration) vessels per pumpout or 2 to 6 times more pumpouts per vessel than the EPA recommends for a NDZ petition

12 Recreational Pumpouts and Moorages

13 Commercial Vessels Ocean-going transits: 2,937 Table 3. Oceangoing Vessel Transits into Puget Sound for a Vessel Type Number of Transits Auto Carriers 188 Bulk Carriers 310 Container Ships 1,336 Cruise Ships 167 General Cargo 169 Oceangoing Tugs 146 Miscellaneous 16 Reefer 5 Roll on Roll Off 133 Tanker 467 Total 2,937 Non-Ocean Going vessels: 678 Table 4. Puget Sound Harbor Vessel Population for a Harbor Craft Vessel Type Number of Vessels Commercial Fishing 347 Ocean Tugboats 68 Harbor Tugboats 60 Excursion 60 Government 52 Ferry 45 Workboat 27 Assist and Escort Tugboats 19 Total 678 Data source: George Washington University AIS, 2005

14 How is Waste Handled on Commercial Vessels Currently compliant with at sea discharges, pumpouts or pumper trucks : Cargo ships, tankers, large cruise ships, military vessels, ferries ~15 commercial pumpouts Challenge to comply: Tugs and barges (~100), NOAA research vessels (2-3), small passenger vessels (6-8), some commercial fishing vessels

15 Stakeholders Ecology, EPA, WA DOH, State Parks, Puget Sound Partnership, recreational vessels operators and associations (RBAW, WBA, NMTA), commercial vessel operators and associations (American Waterways Operators), NDZ Marine Alliance, Puget Soundkeepers Alliance, Clean Marina Program, tribes, WA Sea Grant, WDFW, WA DNR, Futurewise, Ports, marinas, and more.

16 Draft Petition 2014 Draft Petition out for 60-day public comment Received >26,000 e- mails/letters Ecology completed a Response to Comments >25,000 were form letters, 866 individualized 25,466 in support of Draft Petition; 524 expressed opposition or concerns

17 Puget Sound NDZ Commercial Vessel Economic Evaluation Commercial vessel operators will bear additional expenses if NDZ Retrofit costs significant for tugboats, commercial fishing vessels and small passenger vessels May be other costs revenue losses from disruption of operations; loss of space, small passenger vessel classification change Holding tank sizing varies, many already holding tanks

18 Analysis of Water and Pollution Movement in Puget Sound Discharge locations are connected to sensitive areas, and any waste discharged at these locations would eventually be transported to nearshore areas, including shellfish beds within ½ day to 1 day. Depending on initial concentration, result in dilution factors that may not meet marine water quality standard for fecal coliform bacteria.

19 Implementation Planning Fleshing out details for implementation planning if NDZ occurs, committee and plan in place Outreach/Education key strategy to compliance Enforcement combination of USCG, State and local authority Long-term evaluate success by volume pumped out, shellfish beds opened, boater surveys, continued work on pumpout availability and outreach, WQ comparisons

20 Status Working on adding ~2 additional commercial pumpouts Preparing for final determination on geographic extent and delayed implementation for certain commercial vessels list of considerations Drafting the final petition language Preparing implementation strategy for potential determination by EPA Communication Plan/Roll-out Potential Final petition in March 2016

21 Map of draft proposed geographic extent of NDZ in draft petition The western boundary of the NDZ would be the exit of the Strait of Juan de Fuca near the entrance of Admiralty Inlet. This boundary is known and visible to vessel operators as it is the line between New Dungeness lighthouse and Discovery Island lighthouse. The northern boundary would the border with Canada and heading south including all marine waters down to the south end of the south sound and Hood Canal. The fresh waters of Lake Washington, Lake Union and connecting waters between and to Puget Sound would be included.

22 Questions and Discussion For more information: Amy Jankowiak Department of Ecology Municipal Compliance and Vessel Sewage Prevention Specialist (425) No Discharge Zone Website:

23 Shoreline Armoring Update Northwest Straits Commission, January 29, 2016 Photo: Hugh Shipman, ECY 1

24 Puget Sound Partnership 2011 Shoreline Armoring Target(s) By 2020, remove more armor than is newly constructed Avoid new armor on feeder bluffs, and focus removals on feeder bluffs Utilize soft shore stabilization where feasible

25 Puget Sound Shoreline ~2500 miles San Juan Whatcom Current conditions* Skagit 666 miles armored (27%) Island highest in King (73%) & Pierce (51%) Clallam Jefferson Snohomish ~ 50 miles of RR on east shore of central PS lowest in San Juan (4%) & Jefferson (11%) Kitsap King Mason * PSNERP data Thurston Pierce Armored Shoreline

26 25000 Puget Sound Armor New Replace Remove Armor Length (ft.) Year

27 Who s constructing new armor and Who s removing it? New Armor (ft.) by Applicant Type Agriculture 3% Commercial/Ind. 3% Armor Removal (ft.) by Applicant Type Single Family Residence 9% Commercial/Ind. 4% Government 21% Single Family Residence 67% Multiple Family Use 2% Non-Profit Agency Private 4% Non-Profit Agency Private 37% Government 50%

28 New Armor by County % of New Armor Length (ft.) Clallam Island Jefferson King Kitsap Mason Pierce San Juan Skagit Snohomish Thurston Whatcom County

29 Shoreline Master Programs Rules in new SMPs for all new stabilization applications: Avoid: Demonstrate need for stabilization (geotech report) Minimize: Use softest approach feasible for the site Compensate: Offset impacts (planting, beach nourishment) Rules apply statewide. Approach was derived from SMPs adopted in 1990s. 7

30 Stabilization Continuum Photos: Hugh Shipman, ECY 8

31 New SMPs for Puget Sound just coming online Average age of new SMPs is less than 3 years. Almost half were completed since Little data yet to assess new SMPs Done Not Done Total Cities Counties

32 New Hydraulic Code Regulations Bank Protection in Saltwater Areas (WAC ) July 1, 2015 Marine Shoreline Design Guidance as appropriate methods for design Define soft approaches: 85% project area constructed of naturally occurring materials Requires designs to use the least impacting, technically feasible alternative Applications for new or replacement bulkheads: requires site assessment, alternatives analysis, and design rationale May require projects to incorporate beach nourishment, large wood or native vegetation as mitigation

33 Recent NEP funded projects MSDG booklet shoreline owner audiences. Standardized approaches for assessment of need and alternative methods, including soft approaches. Social Science Research & shore-friendly web site identify key information, decision points, tools, and incentives to motivate residential shoreline owners to choose alternatives to armor. Mapping of PS Feeder Bluffs comprehensive mapping for guiding improved management Research on Impacts of Armoring & monitoring removal paired site data on impacts to food webs, shellfish, forage fish, and habitat. TACT Kitsap County, San Juan County & WDFW Troubleshooting Action Planning Course Correction Tracking and Monitoring

34 TACT Report: Potential Actions Hold partners accountable for measures that asses armoring and no net loss of shoreline function through integrated tracking systems. Integrate shoreline work into Strategic Initiatives as a cross-cutting action and/or draft Implementation Strategy to clarify priority actions. Enhance communication strategies to public and decision makers. Support and promote training and technical assistance to local partners Consider budget package to support work. 12

35 Puget Sound Recovery Council Subcommittee commissioned a report on Shoreline Management Act and Shoreline Master Programs: 1) How do each of the studied jurisdictions permit or allow for shoreline modification to take place? 2) How do jurisdictions define, implement, and monitor the policy of no net loss (NNL) of ecological function? 3) Generally, how and to what extent is data on permitted activities and the implementation of NNL being collected and used?

36 PSRC: Select Findings Repair/replacement projects are largely exempt from shoreline permitting. Permitting decisions do not fully evaluate ecological impacts and do not adequately evaluate the relationship of the project to NNL at various scales. Little is known to what extent jurisdictions identify, evaluate, and make decisions based upon data and how NNL determinations are made. County data generally not used in determining compliance with NNL policies at either project or jurisdiction-wide scale. Discrepancies in the NNL do not come from how the policies are written or defined, but in how they are implemented. Affirmed previous findings (e.g., bulk of shoreline armoring projects are repair and replacement, regulations require a demonstration of need, etc.).

37 WDFW/Ecology Proposed NTA NTA seeks to advance findings and recommendations of NEP reports, TACT and Salmon Recovery Council. Goal: Improve implementation of marine shoreline stabilization regulations to achieve Armoring Vital Sign. Develop a systematic approach to document criteria used to asses permitting: 1) Is there a demonstrated need for stabilization; and, 2) where stabilization is needed, does project use least impactful, technically-feasible alternative. Key objectives: Transparency in process; Identify information gaps; Create a formal feedback loop; Document standard operating procedures. Process: Workshops and forums with stakeholders and tribes to inform progress. 15

38 Questions and Discussion For more information: Tim Gates Shoreline Policy Lead Department of Ecology (360) Ecology Soft Shoreline Stabilization: Ecology Shoreline Master Program Handbook, Chapter 15, Shoreline Stabilization: 16