MultiSpecies Salmon Recovery Plan Comments

Comments on Puget Sound Salmon Plan -March 16, 2006
To: Elizabeth Babcock, National Marine Fisheries Service, Salmon Recovery Division
7600 Sandpoint Way NE, Seattle, WA 98115 PugetSoundPlan.nwr@noaa.gov

To: Elizabeth Babcock, Salmon Recovery Planners and Those interested in Saving Salmon:
As a resident of Island County, who has spent the past five years educating, organizing and fighting cooperatively with several organizations to end pollution of wetlands, streams and near shore habitats by stopping the application of herbicides by Island County Public Works and Washington State Department of Transportation (WSDOT) for roadside vegetation control, have knowledge that could contribute to a successful Salmon Recovery Plan.
I am thankful to the individuals, Tribes, local governments and organizations that have put an immense amount of energy, time and thought into the current draft documents. Even though I contribute to and read regularly the South Whidbey Record and the Seattle P.I., last month was the first that I had heard about the existence of the Salmon Recovery Plan.
There are statements made in the WIRA 6 draft that are a stretch of the truth. Island County’s Critical Areas Ordinance adopted in 1998 has been rejected by the Growth Management Hearings Board, The Court of Appeals and the State Supreme Court by upholding the Court of Appeals ruling. Island County has yet to take corrective measures to come into compliance with the GMA. The Island County Commissioners paid former Executive Director of Building Contractors, attorney Keith Dearborn $1.5 million to write a developer friendly GMA and to fight having to implement a compliant GMA and Critical Areas Ordinance. They continue to obstruct obeying the law and put up any obstacles they can think up rather than acting to enable actual protection of wetlands and near shore habitats. Contrary to Court mandates a GMA compliant Land Use Constitution has yet to be completed and implemented in Island County. With approximately 138 wetlands, multiple streams and unmapped sensitive areas on five islands this is very important and has a direct bearing on a Salmon Recovery Plan having any hope of success.
A primary requirement for a successful Salmon Recovery Plan in Island County is a willing landowner. (WIRA6, C. Commitments and Conditions Needed for Salmon Recovery, page 65 under Board of Island County Commissioners.) I don’t have much hope for success. Nor do others with a history of twenty-five years of environmental activism that call this draft Plan a “do nothing plan”. Multiple times WRIA 6 Multi-Species Salmon Recovery Plan refers to encouraging landowners to be responsible for the success of this plan but specifically how this is to be accomplished, funded or who specifically will be responsible to educate the landowner and community is left out. I did not see a commitment by the County Commissioners to any action other that what others could do and what a willing landowner would provide but not how they would specifically become an educated willing landowner acting responsibly to save salmon.
Two current examples of development trumping environmental stewardship occurred at the March 13th meeting of the County Commissioners. A change of designation of 70 acres of pristine forest and wetlands on South Whidbey from Designated Forest to Timber Land was made it so that it could be subdivided into ten acre parcels for timber harvest, for sale and home development. Future landowners would have to decide to save the wetlands. Designations of two other tracks on Camano Island were also approved. One on Camano Island has a wetland that shows “the presence of a regulated (fish) bearing stream and associated wetland”. This puts the property under the jurisdiction of the Forest Management Plan with no mention of any of these areas being subject to a Critical Area Ordinance. When no one, who had read the legal notices in the Whidbey News Times, objected, the request for a change of designation was Okayed. Too many times to count, a single organization has been present, to give the only oversight and objection to development plans that would have been otherwise approved.
The second example is that currently a number of streams going from wetlands to Puget Sound near shore habitats on Camano Island have 75 times the allowable fecal coliform levels as per EPA regulations. Directly west of Camano Island, Holmes Harbor is currently closed to shell fish harvest because of high fecal coliform levels. The source of pollution has yet to be identified. This occurs multiple times a year adjacent to Freeland and Nichols Brothers Boat Builders.
In the decade of the 1990s approximately 10,000 gallons of herbicides/pesticides were applied to Island County by multiple government agencies, business and private landowners. April 2, 2001 I presented 175 pages of scientific studies documenting links to herbicides/pesticides (pesticides is often used interchangeably with herbicides as an identifier) to a decrease in reproductively in salmon and multiple species; numerous serious illnesses in children; and adults as official comments to Public Works roadside vegetation control program. The peer reviewed studies proving salmon habitat of the Endangered Chinook were at risk was not enough for the County Commissioners to make a change to stop the harmful practice. A year of educating and organizing the population to communicate to the Commissioners to stop using herbicides for roadside vegetation control resulted in a unanimous resolution being passed to stop their use April 1, 2002. Public Works continues integrated pest management (IMP) along County roads. (WIRA 6, page 65, C. Commitments and Conditions Needed for Salmon Recovery, Public Works)
I did not find within Volume 1 of the overall draft Puget Sound Salmon Recovery Plan or in the WRIA 6 (Whidbey and Camano Islands) any mention or intent to decrease use of endocrine disruptors chemicals, i.e., organophosphates. Island County is one of only six Counties adjacent to Puget Sound and Hood Canal that does not apply herbicides to roadsides for vegetation control. Although WSDOT claims an 40% reduction in herbicide use on state routes in WIRA 6, WSDOT applies thousands of pounds of various organophosphates on state routes through out the Puget Sound basin and adjacent to Hood Canal. Despite multiple educational conversations and communications WSDOT continues to spray herbicides around guardrails which often are uphill from wetlands, streams and Puget Sound without testing for the presence of adverse effects of the chemicals in those water resources.
WSDOT’s Risk Assessment, which was done after my 175 page submission of scientific peer reviewed studies, 2,000 signatures on petitions to stop spray roadsides for vegetation control and Island County’s Resolution to not spray, WSDOT did not address the studies, the endocrine disruption aspects of herbicides used, nor include in the Risk Assessment those studies and Washington Toxics Coalition’s 17 pages of comments. WSDOT found WA Toxics comments “too complete and comprehensive” to be included in the final Risk Assessment. To show no or little risk WSDOT used only Chemical Corporations data and the often “falsified studies” (reference PBS’s Trade Secrets March 26, 2001 broadcast documenting such) submitted to the EPA for registration® of formulations. None of the “inert” adjuvant, surfactants and “Trade Secret” ingredients were studied, nor were the complete formulations studied but only the “Active Ingredients” which often make up a small percentage of the herbicide formulation. Possible increased toxicity of combinations of formulations often used together have not been tested. Some of the inerts: diesel, soaps and chemicals like POEA (polyethoxylaled tallowamine) stay in the environment longer and cause more measurable harm than the organophosphates, such as glyphosate used in RoundUp® and Rodeo®, its water weed counterpart. A Federal Court ruled that Chemical Corporations hiding ingredients under “Trade Secrets” was no longer a valid reason and the data had to be made available. Enforcement of this ruling is needed, but not done.
Organophosphates, such as glyphosate the “Active Ingredient”, found in Rodeo®, RoundUp®, Weed-B-Gone® and others feminize males by affecting the hormones in multiple species. This decreases sperm counts, limits achieving sexual, reproductive maturity and thus produces a decrease in species, especially salmon. Rodeo® application is contraindicated for salmon recovery or survival as it pollutes the near shore habitats critical for food and is an organophosphate. Endocrine disrupting toxic chemicals applied in the environment uptake in the food chain, thus effecting the reproduction of herring, etc. and concentrates in foraging young salmonid doing the damage of limiting sexual maturity and reproduction from a very young age, thus causing extreme harm to the species and what eats salmon, etc.
Spartina removal by hand was first organized by Lori Oneal with the Scatchet Head community at minus summer tides and resulted in the majority of the invasive tideland weed being eliminated in that area. Island County, with the Department of Agriculture, will be applying twenty gallons of Rodeo® for Spartina control into the near shore critical habitats of WIRA 6 this year. No chemical application of Rodeo® has had as great a success as the hand removal. (Reference: Washington Toxics Coalition booklet, Tales of Toxicity: A Grassroots approach to fighting Toxic Pollution, by Kari Mosden, Kate Nelson and Hayden Bass 2005, is available at www.watoxics.org. and Sno-Isle Libraries.
Denmark has banned RoundUp® from use in its country because of its migration into the drinking water contrary to claims by the manufacture. New York State has declared the advertisements of RoundUp® false and misleading and has banned them from the state.
Recommendations I would make are:
1) Make the success of the Salmon Recovery Plan in WIRA 6 dependent on more than a “willing landowner” that at present is uneducated to this fact. Include within tax statements educational materials as to specifically what the landowner can do to support salmon recovery and protection. Offer that upon signing up to be an active educated salmon recovery landowner by pledging to follow some simple guidelines; they choose to have a tenth of a percent of their taxes to go to salmon protection; and they would receive a yard sign acknowledging that a “Salmon Friendly” landowner lives here.
2) Include in the educational material that yard care products registered by the EPA stating that the buyer is libel for any damage are likely to damage salmon. Ask that they pledge to not use: RoundUp®, Weed-B-Gone®, 2,4,D and other weed and turf builders that offer to kill weeds, pests, insects, moss, etc. as poison does not stay where it is put. Include information on alternative methods of pest, weed and moss control and suggest that a less than perfect lawn is a sign of a good salmon steward. Promote native plant yards as smarter than green lawns.
3) With the weight of your organization and the validity of the scientific reports on the harm done to salmon (request scientific studies of what I and others such as Washington Toxics have) that the Washington Department of Agriculture, Department of Ecology and Washington Department of Transportation stop using herbicides/pesticides for weed control. Include this information in the final Puget Sound Salmon Recovery Plan. I have already sent such a letter to the Governor regarding the Puget Sound Partnership program goals being unachievable as long as toxic chemicals continue to be used by the state uphill of and in Puget Sound and Hood Canal.
4) An immediate stop to the use of Rodeo® being used in critical near shore waters needs to be put into place. Contact: Department of Agriculture, Spartina Program, P.O. Box 42560, Olympia, WA 98504 and Island County Noxious Weed Control Board, Susan Horton, Program Coordinator, P.O. Box 5000, Coupeville, WA 98239-5000. Monies used to purchase the 20 gallons of Rodeo® for attempted Spartina control, would be better used organizing hand removal at summer minus tides. Year after year toxic chemicals are the primary tool used and still the problem is there as are the effects of the toxic chemicals on salmon recovery.

Respectfully submitted, Theresa Marie Gandhi