Cooke Aquaculture Pacific NPDES permit applications to raise steelhead

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Comment From: Elsie Love

6/08/20 @ 5:00 PM
Dear Ms. Niewolny,
Cooke has failed repetitively to maintain the integrity of their nets containing Atlantic salmon, a non-native species they should have been motivated to contain.
Based on Cooke's history of negligence and blatant disregard to protoc...↓
Thank you for taking public comment on this matter.

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Comment From: Kathy Duprey

6/08/20 @ 5:00 PM
I support Amy Trainer, Environmental Policy Director for Swinomish Indian Tribal Community
and her concerns. I am a resident of the neighborhood where Cooke Aquaculture is located.
Sincerely,
Kathy Duprey
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Comment From: Kären Ahern

6/08/20 @ 4:31 PM
A thorough Environmental Impact Study needs to be done. How can we take chances with our Native Salmon whose health is already compromised? We know how easily disease can be spread and the vulnerability of Native Fish and chances for farmed fish to e...↓
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Comment From: Linda Chaves

6/08/20 @ 4:28 PM
I am in support of the Cooke Pacific Aquaculture request to change the species to be cultured in their net pens from Atlantic salmon to sterile triploid rainbow trout/steelhead.

I am a NOAA Fisheries retiree where, over the course of over thirty years...↓

The FAO 2020 Status of Fisheries and Aquaculture report states that "To ensure a food secure future for all, the fisheries and aquaculture sector is key." Aquaculture, whether for steelhead, Atlantic salmon, or any other fisheries product, is an important contributor to food security around the world. The United States, with the largest EEZ in the world and extensive state waters ranks only 17th in the world for aquaculture production, however, and contributes very little to global aquaculture production. Domestic seafood consumption relies on imports for over 90 percent of its seafood with over 50 percent of imports estimated to be farmed. Our seafood supply is not secure!

The Cooke Aquaculture project, should be an important element of the Washington State economy now and in the future. With increasing global population, static or decreasing wild capture fisheries, growing demand for existing wild and farmed seafood, the only option for increasing supply is aquaculture. Washington State should be an active player both within state waters and offshore to provide safe and healthy U.S.-produced product, reduce reliance on imports, and provide products for the rest of the United States and export. Cooke Aquaculture can do this in a safe and responsible manner while providing year-round employment, not only for the farm staff, but also for staffing of allied support services including seafood processing which itself employs 25 people.

Thank you for the opportunity to comment. I would hope that the Department of Ecology will base its decisions on peer-reviewed scientific papers addressing the issues of concern, rather than popular misconceptions and beliefs. The Cooke SEPA Checklist and Attachments document includes many peer-reviewed scientific papers that address the concerns that have been raised by the opposition.

Note: I am not now, nor have ever been, paid by any segment of the fisheries, aquaculture, or seafood industry to support or lobby for any specific position.

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Comment From: ProFish International Inc. (Wally Pereyra)

6/08/20 @ 4:11 PM
Wally Pereyra, Owner and Chairman, ProFish International Inc. - Please find attached my letter in full support of Cooke Aquaculture Pacific's request for a modification to its NPDES permit to allow for the raising of sterile native steelhead trout ...↓
Sincerely,
Wally Pereyra
Owner and Chairman
ProFish International Inc.
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Comment From: Kim Beck

6/08/20 @ 3:20 PM
There is no dispute that net pens cause harm to marine waters. I strongly oppose the proposed permit modification. Changing the species does not lessen the environmental impact of raising fish in a net pen environment. The concern about pollutants (f...↓
As a Washington coast resident, I endorse the position of Wild Fish Conservancy and others who urge a stay of proceedings until their SEPA challenge is complete, and their arguments against issuance of a modified permit based on the environmental risks it poses and the survival of native species. Many of these species are already threatened or endangered-- including several species of salmon and southern resident killer whales.
Please remember Cooke Aquaculture's previous SERIOUS violations. There is no need to gve them another chance. Do not permit these applications. Give the Salish Sea a chance to recover!
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Comment From: Cooke Aquaculture Pacific (Kevin Bright)

6/08/20 @ 3:09 PM
Re: Public comment in support of the Cooke Aquaculture Pacific requested NPDES permit modifications to rear native finfish in marine net pens

Dear Ms. Niewolny:

Thank you for the opportunity to comment on the proposed NPDES permit modifications. As you...↓
The net pen cultivation techniques, feed ingredients, fish health practices, feed delivery systems and feed monitoring procedures for rearing all-female triploid Rainbow trout/steelhead will be fundamentally the same as those we have used in the culturing of Atlantic salmon. Both fish have the same or very similar physiological characteristics, and the same or similar biological and nutritional requirements. Modern salmonid feeds are composed of highly digestible ingredients that are specifically formulated for optimal growth and meeting the metabolic requirements of the cultured stocks. The commercial feeds used for both salmon and trout are nearly identical, with most trout diets possibly containing slightly lower lipid levels than some commercial salmon feeds. Feeding the fish is both an art and a science, and Cooke has a team of highly dedicated individuals to perform that duty during the 450 plus days (15 to 22 month) of the fish's marine growing phase. Farm managers, feeding technicians and farm site employees work hard every day at ensuring the fish are being well cared for and that includes being properly fed. This is agriculture and the people we employ are farmers at heart, and just like a farmer who takes pride in successfully growing a beautiful crop of apples, wheat or cattle, our employees are gratified by what they are doing. Their goal at the farm sites is to carefully track the fish populations, the daily feed amounts, the growth rates and the water quality in order to achieve the best feed conversion rate for their fish. This means feeding the fish in a way that minimizes excess or wasted feed and optimizing the feeding process from start to finish. Irrespective of your opinion about salmon farming, we owe a debt of gratitude to all the people involved in agriculture, fishing, harvesting, processing, transporting and providing food security for our communities, especially in the recent very challenging times we are all facing.

Based on our growth projections for all-female triploid steelhead, the marine growing cycle will be shorter by 4 to 7 months compared to the previous production cycle of Atlantic salmon. The trout will be harvested at a smaller average weight (approximately 7 to 8 pounds) rather than what is primarily the average harvest weight (11 -12 pounds) for Atlantic salmon. The market preference for smaller average weight trout coupled with the projected growth rates of the all-female triploid steelhead will result in the total standing stock (biomass level) of these farm sites to be less per cycle than previously was achieved during past Atlantic salmon production cycles. The shorter production cycle for the trout (first fish in-last fish out) will in turn also shorten the time between net pen fallowing cycles. Fallowing a farm location is a well-known and widely used agricultural practice that achieves several biological benefits to the health and welfare of the crops being raised. There are also benefits to the surrounding environment from the biological break in production during routine fallowing periods.

Because there will be no substantive differences in the feed ingredients, a reduction in total standing biomass per cycle, and an increase in the fallowing frequency, there is no reason to believe these sites will not continue to meet the state water quality requirements and sediment management standards which they have been meeting since 1996 when the first NPDES permits were issued.

We are hopeful this change begins a new chapter in Washington's marine aquaculture industry. Cooke believes that as a society we will require both sustainable capture fisheries and improved aquaculture production to meet the future challenges of global food security. Both of these forms of food production currently coexist and are vital in meeting future demands. The human population is projected to increase by 2 billion people over the next 30 years from 7.7 billion to 9.8 billion (UN FAO, 2018). An increasing population will only put further pressure on global capture fisheries which currently are at their maximum sustainable yield. We believe that our proposal to raise all-female triploid steelhead in the marine net pens is the next step forward in meeting increasing demands for healthy, affordable and sustainably produced seafood while continuing to reduce risks to the environment in which we grow our fish.

Thank you again for the opportunity to comment.

Sincerely,

Kevin Bright, Permit Coordinator
Cooke Aquaculture Pacific

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Comment From: Anonymous Anonymous

6/08/20 @ 2:46 PM
There are clearly anti-aquaculture groups with ulterior motives (ie. $$$) that claim that net pen aquaculture is harmful for the environment or that the fish being cultured pass rampant disease to the native fish stocks. Unfortunately these groups li...↓
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Comment From: Emily Neufeld

6/08/20 @ 2:40 PM
Given Cooke's history of letting salmon escape into the sound in 2017, they do not deserve a permit to raise steelhead. Please do allow them the chance to cause more negative effects to the ecosystem.
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Comment From: Swinomish Indian Tribal Commun... (Amy Trainer)

6/08/20 @ 2:24 PM
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Comment From: Skagit Audubon Society (Jeff Osmundson)

6/08/20 @ 2:02 PM
Please accept the attached comment letter from Skagit Audubon Society.
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Comment From: Evergreen Islands (Tom Glade)

6/08/20 @ 2:00 PM
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Comment From: Ann Prezyna

6/08/20 @ 1:50 PM
I am an environmental attorney who worked for nearly 25 years as an attorney in EPA Region 10 in the Office of Regional Counsel. My work included oversight of state NPDES programs. I am also familiar with net pens and the harm that results from the...↓
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Comment From: Rebecca Shapiro

6/08/20 @ 1:47 PM
I am absolutely opposed to the issuance of permits for farming steelhead salmon in Puget sound.
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Comment From: Robert and Myrna Sherman

6/08/20 @ 1:32 PM
We strongly support the "Our Sound Our Salmon" recommendations to deny or, at the very least, delay any permitting action until
pending legal actions are settled.
Cooke has a terrible environmental and safety track record. Letting Cooke farm in the Sa...↓
Potential problems far out weigh any benefits.
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Comment From: Our Sound, Our Salmon (Joshua Rosenau)

6/08/20 @ 1:19 PM
The attached comments and documents were joined by 35 organizations and businesses, raising important material that must be addressed in the NPDES permit review.
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Comment From: Wild Fish Conservancy (Kurt Beardslee)

6/08/20 @ 1:11 PM
Wild Fish Conservancy is grateful for a chance to present important information that should inform the NPDES permit process for these net pens, evidence which should compel the Department of Ecology to initiate a new SEPA review, culminating in a new...↓
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Comment From: anonymous anonymous

6/08/20 @ 1:09 PM
This request is ONLY a modification to change the species being raised. The proposed change to raise pacific, native, sterile, steelhead trout is very reasonable, and I support this modification and the continuation of our local aquaculture industry.
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Comment From: Our Sound, Our Salmon (Joshua Rosenau)

6/08/20 @ 1:05 PM
The attached comments and documents were joined by 35 organizations and businesses, raising important material that must be addressed in the NPDES permit review.
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Comment From: Trevor Janzen

6/08/20 @ 12:52 PM
I support the raising of farmed fish for Cooke aquaculture

Trevor Janzen
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Comment From: Christy Carr

6/08/20 @ 12:38 PM
This letter provides comments on the application to the Washington Department of Ecology (department) by Cooke Aquaculture for Water Quality Discharge Permits (NPDES) associated with farming of steelhead in net pens located in Puget Sound. Specifical...↓

Please note, while I am a current member of the City of Bainbridge Island City Council, I am submitting these comments as an individual.

As background, the City of Bainbridge Island submitted a Shoreline Master Program (SMP) limited amendment related to aquaculture regulations to the department in February 2017. This locally initiated amendment includes two proposed revisions relevant to the NPDES permit: (1) the requirement for a new permit for a change in species and (2) an outright prohibition of new commercial net pen aquaculture facilities. These revisions were proposed, in part, due to potential and known adverse water quality impacts of the existing net pen facilities. It is my understanding that City and department staff are discussing the consistency of the limited amendment with the Shoreline Management Act (SMA) and relevant SMP guidelines.

I urge the department to, at a minimum, delay acting on the application until (1) all related legal challenges are completed (2) the department and other state agencies with jurisdiction conduct a comprehensive policy and scientific review of the impacts of finfish aquaculture in the state's marine waters, and (3) compliance with WAC 173-27-100 is confirmed.

You no doubt have heard from many other commenters on the inadequacy of the scientific review of the impacts of finfish aquaculture in the state's marine waters. Please rectify this deficiency and review the current permit application only if supported by current scientific and technical information.

My comments focus on and reiterate that finfish aquaculture is inconsistent with SMA goals and policies and its implementing rules based on water quality parameters and that compliance with WAC 173-27-100 should be confirmed prior to department permit review.

Water Quality

Based on a review of scientific and technical information, the City's limited amendment proposes changes that are necessary to improve consistency with SMA goals and policies and its implementing rules, including the requirement to ensure the long-term protection of anadromous fish (e.g.; Puget Sound Chinook) habitats and WAC 173-26-241(3)(b)(i)(A) which provides that aquaculture is a preferred use only when consistent with control of pollution and prevention of damage to the environment.

The following review was provided in the City's limited amendment submittal package (February 2017):

The approach in Island County was to include a prohibition in their SMP and revisit anticipated net pen use based on updated state rules for addressing water-dependent uses during their 2020 periodic review. This is the same approach proposed by the City of Bainbridge Island (see, Policy 5.2.2.11), based on the strong evidence of adverse environmental effects of net pen aquaculture reviewed during the limited amendment process and the poor record of permit compliance, a recent (August 2016) permit violation, and a previous major outbreak of Infectious Hematopoietic Necrosis virus (IHNV) at the existing facilities within Bainbridge Island's waters. On September 18, 1996, Ecology issued National Pollutant Discharge Elimination Permit (NPDES) permits to 12 marine salmon net pen operators which had existing facilities located in Puget Sound, including the Orchard Rocks and Fort Ward Net Pen Facilities in Bainbridge Island. At that time, Ecology determined that those facilities did not have a reasonable potential to exceed state water quality standards for dissolved oxygen and turbidity. Eight of these permits were administratively extended, without modification (other than to reflect the change in ownership), in 2007 and again in 2012. Ecology conducted review under the State Environmental Policy Act (SEPA) and issued Determinations of NonSignificance for the net pen permits issued in 1996. Ecology also concluded that the previously permitted facility had complied with SEPA requirements at the local level. Subsequently, the Pollution Control Hearings Board ruled (which ruling was affirmed by the Thurston County Superior Court) that these marine salmon net pen facilities are categorically exempt from the SEPA alternatives analysis. Ecology has therefore determined that the reissuance of this permit is categorically exempt from SEPA pursuant to RCW 43.21C.0383.

The NPDES permits for these facilities have not been updated, including Ecology's reasonable potential analysis to exceed state water quality standards, since 1996, and the environmental impacts of these facilities have never been reviewed at the local (City) level. This is a critical lapse in regulatory oversight, particularly given the operator's poor record of permit compliance and its recent permit violation (see, Ecology ERTS number 666826). The permit violation was caused by the discharge of accumulated solids and marine growth into waters of the state without prior treatment resulting from high pressure washing of nets at the Fort Ward facility. Although the violation resulted in a warning letter from Ecology, it is reflective of the operator's poor record of permit compliance, particularly related to monitoring. Between 2011-2014, the operator failed to submit discharge monitoring reports (DMR) – a requirement of the NPDES permit – over a dozen times (see, Ecology's PARIS website, permit number WA0031534).

Given the operator's history of insufficient monitoring and permit violations related to water quality and the absence of any environmental review of the facilities in over two decades, there is limited evidence that the use is "consistent with control of pollution and prevention to the environment," and the use is therefore not a preferred use in accordance with WAC 173-26-241(3)(b)(i)(A).

In addition to serious concerns over documented water quality degradation and monitoring deficiencies, a major outbreak of IHNV occurred at the net pen facilities in 2012 during prime juvenile salmon and steelhead outmigration. During the outbreak, the operator refused to allow access to the facility to monitor the effects of the outbreak, resulting in limited knowledge on the effects of the outbreak. The net pens and presence of this virus pose a serious threat to ESA-listed anadromous fish in Puget Sound because the crowded pens create an environment in which diseases, pathogens, and parasites can multiply rapidly and spread to wild fish (Wild Fish Conservancy, http://wildfishconservancy.org).

As noted earlier, water-dependent uses – including commercial aquaculture facilities – can be permitted only when they are consistent with the SMA's requirements to ensure the long-term protection of anadromous fish habitats. Given the wide range of scientific evidence documenting the adverse environmental impacts of commercial net pen facilities, and the known harmful effects of the IHNV on anadromous fish, it is most likely that the existing facilities are not meeting the SMA requirements.

In part, Ecology publication 15-06-006 states: Ecology is committed to ensuring that commercial salmon net pens do not put Pacific salmon recovery at risk. Based on the current regulatory and permitting structure and our review of the science, Ecology has found that when commercial net pens are properly sited, operated and monitored to include all necessary safeguards, they are compatible with objectives of the state Shoreline Management Act.

Through the limited amendment process, the City determined that the existing net pen facilities within its jurisdiction are not properly operated and monitored to include all necessary safeguards with regard to water quality protection and the outbreak of the IHNV virus. As such, the City finds that any new commercial net pen facilities, particularly if proposed by the same operator, would likely not be compatible with the SMA's objectives and requirements related to control of pollution and prevention to the environment and long-term protection of anadromous fish habitats. As such, the City proposes to prohibit any new commercial net pen operations and revisit the issue during its periodic review.

While some of the above review is outdated, the department should note that the current net pens are not likely properly sited and have a questionable operational track record and may lack necessary safeguards with regard to water quality protection.

WAC 173-27-100: Revisions to permits

The City of Bainbridge Island's limited amendment includes a revision requiring a new permit when, "The applicant proposes to cultivate a species not included in the original permit." The department, in its informal response to the City's limited amendment, noted this revision is inconsistent with WAC 173-27-100, which states, in part:

A permit revision is required whenever the applicant proposes substantive changes to the design, terms or conditions of a project from that which is approved in the permit. Changes are substantive if they materially alter the project in a manner that relates to its conformance to the terms and conditions of the permit, the master program and/or the policies and provisions of chapter 90.58 RCW. Changes which are not substantive in effect do not require approval of a revision.

The department's informal response stated, "This provision is inconsistent with the permit revision criteria of WAC 173-27-100 which applies to all shoreline permit approvals."

The local jurisdiction; in this case, the City, should be notified of the proposed change of species and provided with detailed plans and text describing proposed changes from the original permit in order to determine, per WAC 173-27-100, that the proposed changes are within the scope and intent of the original permit and are consistent with the applicable SMP and SMA. Per WAC 173-27-100, "Within the scope and intent of the original permit" includes, but is not limited to:

• No additional over water construction is involved except that pier, dock, or float construction may be increased by five hundred square feet or ten percent from the provisions of the original permit, whichever is less;
• The use authorized pursuant to the original permit is not changed; and
• No adverse environmental impact will be caused by the project revision.

Local jurisdiction review is needed to confirm that a change in species is within the scope and intent of the original permit as defined in WAC 173-27-100. The department should delay its review of the permit until compliance with WAC 173-27-100 is confirmed – or, at a minimum – the local jurisdiction's compliance review should be incorporated into the department's review of the NPDES permit.

In summary, please do what the department requires of local jurisdictions and citizens when reviewing and submitting permits for activities within our marine waters: ensure consistency with current scientific and technical information and applicable state laws and guidelines.

Thank you for considering my comments.

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Comment From: Inderjit Bains

6/08/20 @ 12:30 PM
I support the farming of sterile
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Comment From: Inderjit Bains

6/08/20 @ 12:28 PM
I support the farming of sterile
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Comment From: Inderjit Bains

6/08/20 @ 12:25 PM
I support the farming of sterile
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Comment From: Brian Francis

6/08/20 @ 12:24 PM
Ban all factory fish farms immediately , protect our wild salmon!
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Comment From: John Forster

6/08/20 @ 12:12 PM
Dear Sirs,

I just want to reaffirm my support for Cooke Aquaculture's application to grow sterile triploid Rainbow trout in their farms in Washington State instead of Atlantic salmon and I hope you will approve it. Not to do so will result in the exti...↓

For reference, I was the first General Manager of Stolt Sea Farm's salmon farming business in Port Angeles and their salmon hatchery in Rochester starting in 1984. I have worked in aquaculture since 1965 and seen it grow into an industry that now produces half of the world's seafood. It is inevitable that this growth will continue worldwide in the years ahead, providing healthful food and jobs for those who produce it. It would be a tragedy for Washington State to relinquish its leadership position in the U.S. aquaculture industry as a result of unsubstantiated claims by industry opponents.

John Forster BSc, PhD.
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Comment From: Deborah Myers

6/08/20 @ 11:57 AM
I have lived "downstream" from the fish farm for almost 25 years. I oppose the application to allow for the raising of Steelhead in Rich Passage. I am deeply concerned about water quality in Rich passage. Over the many years, I have observed a succes...↓

As a mother, the pollutants in the water concerned me and I never allowed my children to play in the water. The kids would ask me why and I would always tell them the water is too polluted. This is a shame in such a beautiful area. Please do not allow this polluting operation to continue in Rich Passage.
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Comment From: Emma Helverson

6/08/20 @ 11:28 AM
Hello,

Thank you for the opportunity to comment on and help inform the scope of Cooke Aquaculture's National Pollutant Discharge Elimination System (NPDES) permits. Based on the well-documented risks posed by this industry, Cooke Aquaculture should no...↓

While the legislature moved to ban Atlantic salmon net pens, I believe it's clear what the legislature and public's intent was with the passage of this law-- to prevent the unacceptable risks associated with the only large-scale, commercial open water finfish aquaculture that existed at the time and respecting the few small-scale tribal operations that exist.

Furthermore, all of the risks posed by Atlantic salmon net pens-- significant discharge of untreated pollutants and chemicals, amplification and spread of pathogens, and various risks posed by escapes --remain the same for this new form of steelhead and may even be increased with native species, as acknowledged by WDFW's Dr. Kenneth Warheit in his testimony to the legislature in 2017-18. If the risks of Atlantic salmon were considered unacceptable by the legislature and the risks associated with steelhead are the same or heightened, it seems reckless and in direct opposition of the precautionary principle for Ecology and other state agencies to try to limit the scope or review of this new proposal to the change of species only.

With Southern Resident killer whales starving to death and the coastwide decline of our wild salmon and steelhead populations, it seems inconceivable that the State would continue to work to mitigate the significant risks of this industry, a feat I hold on the same level as other state's working to "green" their coal industries. Like coal, open water net pens pose too great a risk to our health and environment and I hope that Washington State agencies soon recognize that open water net pens fall into this category.

I urge Ecology not to grant these permits and recognize that this industry is far too risky for Puget Sound and in direct contrast to the recovery of wild salmonids and Southern Resident killer whales, and Washington's goals for improving water quality in Puget Sound. If the agency decides to move forward and consider this proposal, I hope you will make a concerted and rigorous effort to fully consider the risks associated with this proposal and specifically consider the following points:

1. While not a scientific argument, I think it's extremely relevant to consider Cooke's reputation as a company and past actions in order to determine if Ecology is capable of enforcing the rules set forth by the NPDES permits.

First, Cooke is an extremely litigious company that in the past four years alone has 1). threatened during legislative testimony to sue the state under NAFTA if a bill passed banning nonnative finfish aquaculture; 2) appealed government actions including lease terminations and fines; 3) used cease and desist letters to silence local environmental advocates, including during the public comment period that determined the future of their new proposal to expand aquaculture to steelhead. Engaging in business with a company that uses litigation to influence and intimidate legislators, government officials, and Washington citizens is not in the best interest of public and puts our State at risk of costly lawsuits.

Second, regulatory oversight of this industry largely relies on Cooke self-monitoring and self-reporting violations. Over the years, Cooke has proven themselves to be particularly unscrupulous when it comes to reporting problems or violations at their pens, violations that are often reported by landowners or environmental organizations. Under this system Cooke neglected to maintain their facilities as required, resulting in the Cypress Island collapse and afterward lied to government officials about the cause. Cooke never reported that they were importing, planting, and amplifying exotic Piscine Reovirus (PRV) in their Puget Sound net pens (a virus the state has still never tested for in stocked Puget Sound net pens). In October 2019, during the SEPA review of Cooke's proposal to expand to steelhead when one would expect the company to be on their best behavior, there was a partial failure of one of the Bainbridge net pens that was not immediately reported to the State. It's clear that Cooke cannot be trusted to self-monitor or report. Ecology must demonstrate clearly that any rules set forth in the NPDES permits will be fully enforced.

Third, this company has a history in Puget Sound and around the world of violating local and federal environmental laws. Cooke pleaded guilty to illegal pesticide use in Canada resulting in one of the largest fines ever levied under Canada's Fisheries Act. More recently, the federal government threatened a moratorium of the menhaden fishery in Chesapeake Bay after Cooke-owned Omega Protein, a single company, harvested 30% more menhaden allowed under a management plan adopted by the Atlantic States Marine Fisheries Commission. I bring these three points up to demonstrate Cooke's lack of regard for following laws, such as those set by NPDES permits which would require Ecology to develop clear strategies for enforcement of any regulations set by the NPDES permits.

Given the fragility of our wild salmonid and killer whale populations and Cooke's obvious disregard for laws that protect them, I believe our State agencies should give greater priority to the will of the public whose resources are at risk, instead of private companies who have demonstrated a failure to abide by local and federal environmental and water quality laws.

2. NPDES permits should not be granted before the ongoing SEPA litigation against the Department of Fish and Wildlife (WDFW) is concluded.

WDFW's State Environmental Policy Act (SEPA) mitigated determination of nonsignificance (MDNS) and the process used to come to that determination is currently being legally challenged in Washington State court. That determination was largely based off the 1990 Environmental Impact Statement (EIS) and may be found to have violated SEPA. If WDFW is found in violation for failing to conduct appropriate environmental review, a State court could invalidate the current MDNS and initial permits granted to Cooke Aquaculture during SEPA, and instead require additional environmental review in the form of an EIS. If this is the case, it is likely that this additional review would reveal new, pertinent information regarding water quality and/or pollutants that is relevant to the NPDES permit process. For this reason, Ecology should not grant or finalize Cooke's NPDES permits until the Court makes it's ruling.

2. Ecology should not limit the scope of the permits to the change in species, and instead consider all risks associated with open water net pen aquaculture.

The last formal environmental review of the impact net pen aquaculture poses to the environment was the Environmental Impact Statement (EIS) completed in 1990. Since then there has been significant new research and study on the impacts of net pen aquaculture that has never been formally reviewed by the State. In addition to research, we've seen real examples of the risks this industry poses here in Puget Sound that also need to be considered:

- 2012 outbreak of IHN that spread to all three Bainbridge Island net pens while juvenile salmonids were outmigrating through Rich Passage
- 2017 Cypress Island net pen collapse that released over 300,000 nonnative Atlantic salmon into Puget sound, this later resulted in Cooke paying a $2.75 million settlement in Clean Water Act violations
- 2018 discovery that Cooke had been importing and planting fish infected with exotic Piscine Reovirus (PRV) in their Puget Sound net pens and that nearly 100% of the fish that escaped from Cypress Island were infected
- a 2017 $8,000 fine by Ecology for water quality violations which included among other charges "Failing to correct water quality violations when directed"
- 2019 partial sinking of Cooke's Bainbridge Island net pen, failed to properly report the incident to State agencies
- video footage taken by landowners near Rich Passage showing marine mammals both on and in Cooke Aquaculture's net pens, photos show 100 marine mammals on a single pen at one time (previously submitted to the State by landowners)
- video footage showing Cooke employees disposing of bycatch during harvest (already submitted to the State by Wild Fish Conservancy and landowners who took footage)

Much like our understanding of climate change, we have much more information in 2020 than we did in 1990 and for that reason I believe Ecology cannot rely on assumptions made over three decades ago while drafting these current NPDES comments. The law passed in 2018 by the Washington State legislature set a stricter regulatory regime for marine net pen aquaculture on the grounds that the practice placed too great a risk on the ecosystem. For this reason, it is not sufficient to assume that conditions of the current NPDES application are similar to those of past permits. HB 2957's new standards require re-examining past decisions to hold Cooke Aquaculture to that higher standard of eliminating these risks.

What's more, as a result of our recent law, all of Cooke's Puget Sound net pens were to be removed by 2022 (or 2025 depending on the Port Angeles lease appeal process), and Cooke is currently in the process of harvesting the last Atlantic salmon from their net pens. This means all of the risks posed by Cooke's facilities would have been reduced to zero after their leases expire. As such, and because new leases would not be considered a "renewal", this permit should not consider the pollution impacts in comparison to Cooke's Atlantic salmon net pens but the impact the extension and expansion of net pen aquaculture compared to zero commercial, non-tribal net pen finifish aquaculture.

Ecology should adhere to the new threshold for assessing risk set by the 2018 legislature and not the outdated 1990 EIS, and not limit the scope of the NPDES permits to only the change of species but to all risks associated with pollutants and with the potential to degrade water quality.

3. Ecology must consider the new and unknown risks posed by the change of species.

The steelhead Cooke will use are highly-domesticated and partially-sterile (due to the known failure rate of the triploidy process) and would be considered a pollutant if released. This species poses new and different risks in addition to those posed by the practice itself. Some policies which may have been permitted for Atlantic salmon under the pre-2017 status quo, pose additional risks with the proposal to introduce this new form of steelhead. The prior permitting for these pens and their operations all addressed risks associated with a non-native species. In dealing with this new form of steelhead and Puget Sound's federally-listed steelhead population, different risks apply, and standards laid out in the 1990 EIS, in addition to being outdated, have not been met for these purpose.

I would urge Ecology to consider the specific risks associated with this highly-domesticated and partially-sterile form of steelhead included in the Our Sound, Our Salmon NPDES comments submitted June 8, 2020 as well as the SEPA comments submitted as supporting document.

4. Permits should not be granted without permission from all local tribal nations.

During the 2019 SEPA process the Elwa, Lummi, Samish, Skokomish, Snoqualmie, and Swinomish nations submitted comments expressing serious concerns about Cooke's proposal to expand and extend large-scale commercial net pen aquaculture and calling for a comprehensive environmental impact statement.

No permits should be authorized to Cooke Aquaculture without the full support of Washington's tribal nations whose traditional areas are impacted by pollutants and other risks posed by Cooke's net pens.

Thank you for considering these comments.

Best,
Emma
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Comment From: Conrad Mahnken

6/08/20 @ 11:28 AM
I am Conrad Mahnken, a long-time resident of Bainbridge Island. I am writing in support of the Cooke Pacific Aquaculture request to culture sterile all-female triploid rainbow trout/steelhead rather than Atlantic Salmon at their net pen sites.

I am a...↓
Prior to my retirement I also served as the first NOAA National Aquaculture Coordinator in Washington, D. C. Once retired, I served as a Commissioner on the Washington Department of Fish and Wildlife Commission for a period of eleven years, from 2005 to 2016.

The Cooke proposal to change species should be approved as there is an overwhelming body of peer-reviewed scientific research demonstrating that the impact from properly located and operated net pen facilities is minimal. The concerns that have been raised are over-stated and not based on scientific fact.

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Comment From: Emily Davis

6/08/20 @ 11:15 AM
Please find attached a comment letter from the Snoqualmie Watershed Forum regarding Cooke Aquaculture's proposed NPDES permit modifications.
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Comment From: Cooke Aquaculture Pacific, LLC (Jim Parsons)

6/08/20 @ 11:04 AM
As General Manager for Cooke Aquaculture Pacific's operations in Washington State, I respectfully submit the attached letter of comment regarding our effort to modify our existing and active NPDES Permits.
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Comment From: Katherine O'Hara

6/08/20 @ 10:55 AM
Re: Cooke Aquaculture Pacific NPDES permit application to farm altered steelhead.

I vehemently oppose Cooke's application. Puget Sound is struggling enough with human impacts. It doesn't need more artificial chemicals and drugs, especially antibiot...↓

I believe Cooke does not deserve another chance. Please deny Cooke's application.

Sincerely,
Katherine O'Hara
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Comment From: Raymond RaLonde

6/08/20 @ 10:53 AM
To: Washington Department of Fisheries
From: Raymond RaLonde, Professor Emeritus, University of Alaska, School of Fisheries and Ocean Sciences
Re: Comments on Cooke Aquaculture Steelhead Farm Proposal

Born and raised in Portland, Oregon, my fisheries e...↓
In Alaska, wild stocks of salmon and steelhead are abundant and wide spread. Alaska also has an extensive private non-profit hatchery program producing juvenile salmon that are pen-reared in remote commercial fishing locations prior to release to improve juvenile survival upon release, direct the salmon homing migration to commercial fishing waters, managing and controlling the fishery, and improve harvest quality. In this process of "salmon ranching", we have learned much about pen construction, deployment, and management of pen rearing that is relevant to steelhead farming.
Opposition to fish farming to protect wild runs is almost dilutional. What wild runs? Decades of successful production and stocking steelhead throughout the Pacific Northwest, hatchery enhancement has been so successful that finding a true wild salmon or steelhead is unlikely. As a STEP biologist in Oregon I participated in the wide spread 2-year project to locate wild steelhead by collection scales for circuli pattern analysis, but with no success.
My experience has convinced me that net pen to rearing of fish, has proven to be effective in habitat maintenance and protection of water quality when best practices are used in site selection, rearing pen designs, culture techniques, and environmental monitoring.
The potential for dumping excess fish feed into marine waters is managed by farmers using underwater video and audio surveillance to optimize feed consumption. After all, fish feed is a significant business expense and overfeeding is equivalent throwing money overboard.
Cooke Aquaculture Pacific complies with practicing environmental standards, culture practices, and Washington State regulations for culturing Atlantic Salmon, not native to the State of Washington, and I see no compelling argument that should prevent the farming our own native steelhead.
This breadth of experience has given me convincing evidence that environmentally responsible fish farming is necessary to supply the demand for high quality, healthy fish for our economically and demographically diverse society. Harvest from wild fisheries is simply not able to meet the demand.
In summary, I suggest that Washington spend more effort and funding to fix the real problem of habitat destruction by rehabilitating instream and riparian habitats for juvenile salmon and steelhead trout
Thank you for allowing me to make comments on this project

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Comment From: Jaime Beechum

6/08/20 @ 10:51 AM
Cooke Aquaculture Pacific NPDES permit applications to raise steelhead

I am writing to comment and express concern on the Cooke Aquaculture Pacific NPDES permit application to raise steelhead in the waters of the Puget Sound.

The action of Cooke applyi...↓
In addition, The salmonid population is in a great need for recovery and if there were a net breach the steelhead, with a faster growing rate and domesticated feeding behavior, would create much more of a threat for the local population that has been put under strain for things like polluted waters that come from Cooke's originating fish raising practices. The containment of animals in small areas with one species creates an environment for disease and virus to become more prevalent due to the lack of diversity that supports neutrality. By having diseased fish in open waters creates burdens for the overall marine population, not to mention the health threats to the consumer. If any lesson was learned from the Cypress breach, it would be that new and more holistic approaches to raising fish would be more beneficial to the overall impact of the environment and the consumers of the products being produced. Cooke has shown that it has not been compliant with cleaning equipment, maintenance upkeep and following the Washington State of Ecology requests, so how are we holding the company accountable for any of their requested application? The company should not be able to manage their own standards, since they have show not to uphold the State's requests. I strongly urge the state to reconsider any renewal of permit until Cooke can show a significant upgrade to practices, responsibility to the health of the waters, including revitalization of past incidents and environmental digression.

There is so much evidence out there to support these statements, and it would take many more hours of time I must spend to put a roof over my head and food in my belly to list the expensive reasoning of why these kinds of practices and company allowances should not be permitted. This is the responsibility of the company, and the government to be accountable for.

Thank you for your time,
Jaime Beechum
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Comment From: Mark Roberts

6/08/20 @ 10:21 AM
Please fit rid of all net pen operations in Washington waters!
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Comment From: Sam and Elizabeth Davidson

6/08/20 @ 10:16 AM
We are in complete agreement with Christine Rolfes' letter urging the state to take more time to review the application from Cooke Aquaculture vis a vis raising steelhead salmon in the fishfarm in Rich Passage. We are united in the efforts of the Ri...↓

Sam and Elizabeth Davidson
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Comment From: Anonymous Anonymous

6/08/20 @ 10:16 AM
I am opposed to the ongoing operations on Bainbridge Island. For many years the operations have been inconsistent with managing noise a truck traffic expectations and related safety issues. This sort of operation should not be taking place in a resi...↓
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Comment From: Orca Conservancy (Shari Tarantino)

6/08/20 @ 9:59 AM
Please add the following comments to the record from Orca Conservancy. Thank you.
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Comment From: Kathryn Townsend

6/08/20 @ 9:59 AM
The Washington State Department of Ecology has for many years been serving the industrial aquaculture industry rather than the citizens of Washington State. Left out of the equation are our salmon, orcas, forage fish and all the other species that ar...↓
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Comment From: Wild Steelhead Coalition (Greg Topf)

6/08/20 @ 9:54 AM
On behalf of the Wild Steelhead Coalition and our thousands of members, thank you for accepting the attached comments.

Greg
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Comment From: Peter Becker

6/08/20 @ 9:45 AM
To: Director, Washington State Department of Ecology

Subject: Net Pens for fish/fish holding/fish rearing in the Inland waters of Washington State: in particular; Steelhead Trout in net pens in Port Angeles Harbor

Dear Sirs:

Much misinformation exists a...↓

1. The long, successful role of net pens for fish/fish holding/fish rearing in the inland waters of Washington State

2. The historical presence over the last 150 years of net pens

3. The absolute requirement for net pens

4. Fish pens, fish veterinary science, and disease control

5. The international treaties that require many of the 150 hatcheries in Washington State.

1. Net pens for fish have existed in Port Angeles going back to the existence of fish traps and fish-wheels which were present up until 1937. At that time, due to the excessive take of salmon by the fish trap and fish wheel owners, treaties designed to limit the excessive were signed by Governor Clarence D. Martin and the fish traps and holding pens disappear. As usual the cause was commercial fisheries abuses.

To help restore West Coast Salmon fisheries in the 1970's through the 1990's period, net pens were again employed in numerous bays and coves in Admiralty Inlet and Puget Sound by tribal, private and social groups, from Trout Unlimited and fishing clubs to the Sea Scouts. In the Delayed Release Programs for Pacific Salmon originated by WD Director Milo Moore decades earlier, smolts were often irregularly hand fed with varying results, but were released with no veterinary oversight. Lack of sufficient oversight by Washington State Department of Fisheries certainly was problematic..

2. In then 1970's, the development of Atlantic Salmon rearing facilities at Manchester, WA were established for restoration of East Coast Atlantic Salmon (endangered by habitat destruction on East coast rivers dating back 200 years, as well as over fishing by commercial fishing interest).

Dr. Conrad Mahnken worked with Norwegian interests, and net pen rearing holding of the many recovered separate East Coast river stocks were accomplished with no problems. No danger was anticipated as numerous attempts failed to establish Atlantic Salmon on the west coast dated back to Spencer Baird, Livingston Stone, David Star Jordan and US Bureau of Commercial Fisheries in the post Civil War ->1950's period.


2. Cont'd. The Atlantic Salmon Restoration project was in Washington State because the State had a long history of fish hatchery development and employment for salmon stock restoration and maintenance. This history dated back to the 1880's when the first Sockeye hatchery was built on the Skagit River to offset the loss of fish due to dam construction blocking the upstream access on the Skagit River, all the way into British Columbia, for massive returning runs of Skagit River Sockeye.

The Washington State Constitution written in 1851 forbade "...the construction of dams without fish ladders...". In the 1880's the State chose hatcheries instead

of fish ladders for the Skagit River Dam. The State Commissioner of Fisheries, Mr. A. C. Little, made sure the Skagit Hatcheries was quickly acquired by the U.S. Bureau of Commercial Fisheries, as it appeared the operators were not going to maintain the Skagit hatchery.

A major reason for today's problems remains that the Washington State Department of Fisheries and the US Bureau of Commercial Fisheries, under Livingston Stone and David Star Jordan, did not believe, and assumed that West Coast Salmonids did not return to a "Native Stream', but simply went to the nearest river to spawn. This belief, and resulting practice, persisted until about 1930 in Washington Department of Fisheries, despite several articles by British Columbian Fisheries in the Proceedings of The Royal Society in England detailing fin clipping experiments showing fidelity of salmonid returns to a native watershed. After the 1930s the philosophy was "Salmon without Rivers" (See: J. Lichatowich, Island Press, 1999)

3. The US imports greater than 65% of its seafood and produces ~35% (Gephart, Halley and Branch, PNAS, May 2019). However, it processes most of the production of the Alaskan Prince William Sound Aquaculture Association in China, as it exceeds the capacity of Alaskans to processes it all. Prince William Sound Aquaculture Association produces 43 percent of the Prince William Sound salmon harvest (~34 million Pink Salmo; 3 million Chum; 250 thousand Coho and 1.4 million Sockeye through modern aquaculture). Even in Alaska, there is an absolute requirement to take the commercial pressure off of heavily regulated wild capture fisheries with aquaculture production of fish for food. Many of the "Wild Capture Fisheries" are also heavily supplemented by hatcheries (e.g. the famous "Copper River Sockeye Fishery" (aquaculture style egg boxes and hatchery smolt releases))

4. The very essence of fisheries aquaculture in Washington State has been, and remains, fish pens and farms safety, fish veterinary science, and disease control.

Fish farms have required independent veterinary inspection for the last 20 years if not before.



4. Contd.

The use of fish disease specific vaccines for control of fish diseases worldwide has driven the use, and economics of the only allowed anti-biotic, oxytetracycline (commonly and universally used on pets and humans), so far down that is has become uneconomic to use in feed under the mandated veterinarian's supervision (with any excess feed destroyed when the disease symptoms are gone) in Washington State.

Commercial hatcheries are far ahead of the Washington State Department of Fisheries in the respect of fish disease and health. Commercial hatcheries must operate at a profit to survive and satisfy customers with healthy, disease free stocks. The Washington State Department of Fisheries, Federal and Tribal hatcheries are required to show only they released numbers of fish to satisfy projected fish returns required by treaties.

The Port Angeles Net pen site has never lost a fish due to an escape from the pens in the many decades of its operation, including the incident in the 1970's when a runaway tanker backed down on the fish pens temporarily. That should be proof enough of its safety record and diligence of its several owners.

5. Fish farming is the business of food production, whether Ocean Ranching in Alaska by Prince William Sound Aquaculture Association, net pen rearing of proven safe Atlantic salmon at Port Angeles, Rich Passage and San Juan Island sites, or Steelhead trout in Yakima Tribal Net Pens in the Columbia River.

In Washington State, ocean ranching from 150 Washington State Department of Fisheries, Tribal hatcheries and 12 federal hatcheries raises fish for sport and commercial catch for food and takes pressure off of remaining wild stocks. In several cases these releases are required by international treaties.(Johnson, Graybill,Joseph and Rosenberg, 2010: Bridging National Borders in North America: Transnational and Comparative Histories). United Nations Food and Agriculture Organization recognized in 2017 greater than 34% of world fish stocks are overfished. Aquaculture food production provides relief for wild stocks.

Rearing farmed steelhead trout in the Port Angeles fish farm site will both raise food and reduce pressure on wild stocks as well as the rearing of Atlantic salmon did in the same site and with far LESS risk and pollution than posed by both historical fish trapping and fish pens, up to 1937, and random, uninspected or monitored Delayed Release Net pens of the 1970's through though 1990's.

Unspecified "wild Fish enhancement activities" will require that observed trends in global climate reverse and fall stream temperatures at the start of the spawning runs stay below

20 C, which they have not. The Fraser River to the north of us was above 20 C for days in 2018 during the Sockeye runs there, according to the Department of Fisheries and Oceans Canada, which is threatening to all salmonids, cold water species by definition, attempting to spawn in the Fraser....to the north of us!

Albert Einstein noted:

"We cawhich is exactly what the group opposing the transition to farmed steelhead in the Port Angeles

site is suggesting.

Peter Becker Ph.D. (Oceanography)

BP/S Industries Inc.

Port Angeles, WA

Past Chairman, Marine Technology Society, Puget Sound Chapter (1974-1984)

Past President, Washington Clam Growers Association, Inc. (1978-1984)

Past Treasurer, Olympia Oyster Growers Association, (1979-1984)

Past Chairman, Pacific Aquaculture Caucus Inc. 2004-2014

Past Chairman, Clallam County Marine economic Development Cluster 2000-2008

Past Chairman and Founder, Olympic Chapter, Trout Unlimited, (2004-2009)

Copy Editor "The History of Aquaculture" by Colin Nash, Wiley Blackwell (2011)

Past Chairman, "CoexistProject.US" (for Coastal Marine Spatial Planning) 2011-2013)

Author, "The History of Aquaculture in Washington: 1809-2021, In MS. (2020)n't solve problems by using the same kind of thinking we used when we created them."

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Comment From: Caroline Armon

6/08/20 @ 9:40 AM
I reviewed information, and agree with Our Sound, Our Salmon comments. Also consider Cooke Aquaculture previous violations and history. Do not permit these applications.
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Comment From: Ben Bama

6/08/20 @ 9:36 AM
Thank you for allowing public comment on this. Please do not permit any fish net pens in the Salish Sea for Cooke Aquaculture or anyone else. Cooke already had a catastrophic failure of their Atlantic salmon pen and handled it in a very opaque and ...↓
Thank you for your time.
Ben Bama
SJI
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Comment From: Lynne Jensen

6/08/20 @ 9:11 AM
I am writing to oppose giving Cooke Aquaculture Pacific a permit for another fish farming operation, this time for steelhead, in the Salish Sea/Puget Sound area, and my backyard. After this company's disastrous salmon fish farming breach of their pe...↓
Sincerely, Lynne Jensen, Whidbey Island, WA
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Comment From: Zachary Morrow

6/08/20 @ 8:42 AM
Cooke should not be allowed to modify their NPDES permit in order to raise steelhead. In order for this modification to be acceptable, Cooke would have to be demonstrating a rigorous commitment to safe and well-monitored operation of their net pens. ...↓

Cooke should be held to the highest environmental standards possible given a track record of glaring negligence and the horrific consequences directly stemming from that negligence. How can we justify allowing Cooke to implement Steelhead farming given its record and the alarming fact that its operations remain untenable? They have shown no good faith commitment to acknowledging and rectifying past blunders and no environmental plan that can restore public confidence for the future.

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Comment From: Northwest Aquaculture Alliance (Jeanne Mcknight)

6/08/20 @ 8:30 AM
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Download
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Comment From: James Loran

6/08/20 @ 8:18 AM
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Comment From: Elijah Welch

6/08/20 @ 7:49 AM
I am in opposition of open net pens being operated in the puget sound, and any open water for that matter. Open net pens are breeding grounds for diseases and pests, no matter how much flow there is for the inlet. Our wild salmon are already stressed...↓
I am an OSU student and Puget Sound resident who is against the harm of our waters.
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Comment From: Niki Quester

6/08/20 @ 7:40 AM
Cooke has a history of poor maintenance. Aquaculture is a polluting industry. Puget Sound needs to recover from historical and current polluting industries and activities. Raising steelhead would contribute to pollution problems. Please deny the perm...↓
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Comment From: Stephanie Ross

6/08/20 @ 7:12 AM
Please see attached document for comment.
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Comment From: Jacqui Shaffer

6/08/20 @ 7:03 AM
No species of fish should be farmed in the Puget Sound, whether it be salmon or steelhead. Fish farms negatively affect the wild stocks of fish that remain in the local waters. Please do not allow farmed steelhead or any type of farmed fish in the Sa...↓
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Comment From: Chris Wolfe

6/08/20 @ 6:28 AM
1) Ecology should not authorize Cooke's modified NPDES permits until the ongoing lawsuit challenging the State Environmental Policy Act (SEPA) environmental review process and determination is complete.

2) There is substantial new information that was...↓

3) Ensuring compliance of rules set by NPDES permits is crucial.

4) Washington's landmark 2018 law, HB2957, created a new and stricter regulatory regime for marine net pen aquaculture.

5) Switching species does NOT reduce the rampant daily pollution and water quality risks posed by open water net pen aquaculture. Ecology
should reconsider all water quality risks associated with this industry and not limit the scope of their review to risks associated with a change of species.

5a. Fish Effluent
5b. Fish Waste
5c. Amplification and Discharge of Pathogens (Viruses, Parasites, and Diseases)
5d. Discharge of antibiotics and medical effluent.

6) The change in species poses new and different risks.

7) Escape prevention and the adequacy of Cooke's escape prevention and escape response plans must be carefully considered in this permit process.

8) Ecology should not issue NPDES permits until Cooke has initiated and received agreement from all local, state, federal, and tribal governments.
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Comment From: Chris vanStaalduinen

6/08/20 @ 6:15 AM
Do not allow Cooke to continue to damage our environment and wild fish with their net pens. They have proven they cannot properly manage them.
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Comment From: Mark Leganza

6/08/20 @ 6:11 AM
Please do not allow these people to continue to pollute Puget Sound. They have proven themselves incapable of safely operating these platforms. I have been boating by the Hope Island facility many times and always was amazed it was still afloat.
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Comment From: Diane Bell

6/08/20 @ 6:10 AM
The Cooke Aquaculture Pacific permit to raise penned steelhead in Salish Sea waters should be denied for the following reasons:

1. The high density within salmon pens increases both fish diseases and fish parasites. These can and do spread to our decl...↓

2. The density of penned salmon also leads to heavy nutrient pollution below the pens from animal waste. Nutrient pollution is already a problem in these waters, no need to add to it.

3. Cooke Aquaculture Pacific has proved itself to be an extremely sloppy fish farmer with many many violations and fish escapes. I see no reason to extend new permits to this awful company.

Thank You,
Diane Bell
Seattle

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Comment From: Molly Quade

6/08/20 @ 6:04 AM
Aquaculture has caused problems with the fish population and killer whale population, specifically in the Salish Sea. Just look it up and there's hundreds of resources that back up what the Department of Ecology is trying to do. We don't NEED to have...↓
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Comment From: Lisa McClary

6/08/20 @ 5:52 AM
I am a Washington native living temporarily in Oregon. I am horrified at Cooke Aquaculture's flagrant attempts to get around and violate its water quality permits. Please do not approve Cooke Aquaculture's recent application to modify existing water ...↓

With our dwindling Southern Killer Whale population starving, we cannot accept serious pollution and water quality risks posed by this industry, now or ever, but especially not if fully considered during this permitting process.
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Comment From: Anonymous Anonymous

6/08/20 @ 5:31 AM
I am strongly opposed to the proposed recent application to modify existing water quality permits, authorization required before Cooke can begin farming a highly-domesticated, partially-sterile form of steelhead in their Puget sound net pens. We have...↓
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Comment From: Christine Rolfes

6/08/20 @ 5:27 AM
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Comment From: Anonymous Anonymous

6/08/20 @ 5:17 AM
We think that raising steelhead fish on the coast of Baibridge Island is a bad idea. Years ago the area was not as developed, so some of the points I am about to make may not have been present/relevant for the initial salmon raising lease to be appr...↓

This is now a large residential area. It is also a recreational area visited by people from all over the island, as well as tourists. A commercial business is no longer appropriate.

More houses and a larger population mean more use of the waters for recreational activities. Children as well as adults swim, kayak, paddle-board, etc. in this water. Having over a million fish in the same water means more poop and more chemicals, neither of which are healthy, especially in large quantity. If the pens were not there, some fish would still around but the quantity would be massively reduced and the chemicals would not be present. Reduced fish could mean that the number of sea lions would also smaller, and not present the safety hazard they now do.

Without the fish farm, the number of large trucks that travel the end of Fort Ward Road would be reduced. Unfortunately it is a narrow road that walkers and bikers share with motor vehicles. It is the ONLY way to get to some houses and the south entrance to Fort Ward Park. The many trucks do present a hazard and a danger as they bring supplies and fish and remove them from the farm.

There are certain nuisances involved with the farm, such as noise and occasional foul odors, but these become minor when compared to the problems listed above.

Finally, there is the constant fear of an outbreak. We know from experience that this happens. The release of a million plus fish into the area's water could be catastrophic in many ways.

Thank you for considering our comments when making your decision. I hope you will do what is currently best for our island, its inhabitants, and our visitors.

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Comment From: Snoqualmie Indian Tribe (Matthew Baerwalde )

6/08/20 @ 5:04 AM
Hello Laurie,

On behalf of Snoqualmie Indian Tribe, please accept the attached comments regarding the application to ECY for NPDES Permit Modifications for Cooke Aquaculture marine net pens in the Salish Sea. Thank you for the opportunity to comment.

S...↓
Matt

Matthew J. Baerwalde
Environmental Policy Analyst
Snoqualmie Indian Tribe Environmental & Natural Resources Dept.
mailing: PO Box 969, Snoqualmie WA 98065
physical: 9416 384th Ave SE, Snoqualmie WA 98065
mobile 425-495-4111
mattb@snoqualmietribe.us (he/him/his)

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Comment From: Marcia Lagerloef

6/08/20 @ 4:40 AM
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Comment From: Jeremiah Donier

6/08/20 @ 4:15 AM
For over three weeks' I haven't been able to like to the public comments via your website about Cooke Aquaculture Pacific's water quality permit applications to raise steelhead. This seems an intentional attempt by your agency to prevent public comme...↓
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Comment From: Ethan Muhlestein

6/08/20 @ 3:54 AM
Cooke Aquaculture Pacific has no regard for safety of wild Puget sound steelhead and should not be allowed to raise farmed steelhead in Puget sound. The sound is already suffering historical low wild steelhead and hatchery steelhead counts, the last ...↓
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Comment From: Friends of the San Juans (Lovel Pratt)

6/08/20 @ 3:46 AM
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Comment From: Hugh Mitchell

6/08/20 @ 3:31 AM
Letter of support attached addressing fish disease concerns.
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Comment From: Ryder Thomas

6/08/20 @ 3:29 AM
We have an opportunity to be a leader in the Pacific Northwest in moving away from Net Pen Aquaculture. Net Pen Aquaculture is not the future, and the benefits of allowing Cooke, a Canadian Company, use our waters for their profit, are limited.

At the...↓

Do the right thing. Don't allow Cooke to keep operating in our waters.
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Comment From: Cooper Oswald

6/08/20 @ 3:11 AM
I can't believe I'm still having to add my opinion to this ludicrous proposal. Are you guys not listening to your constituents? The public doesn't want these net pens to continue in our waters. Allowing for Cooke to raise infertile steelhead in Washi...↓
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Comment From: Jason Mouer

6/08/20 @ 3:09 AM
I strongly oppose Cooke Aquaculture's request to farm steelhead in the Puget Sound. The risk to our wild steelhead is too great. Don't trade our wild fishes future for money. Cooke has already demonstrated their inability to safely operate one of the...↓
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Comment From: Steelhead Awareness Movement (Brian Koenig)

6/08/20 @ 2:43 AM
Our organization strongly disagrees with the addition of steelhead net pen farms the Puget sound. The failure of the Atlantic Salmon pens in the orcas islands is a key example of how detrimental fish farms can be to the native fish populations. Pleas...↓
-Brian Koenig
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Comment From: Marilyn Tuohy

6/08/20 @ 2:39 AM
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Comment From: Maine Aquaculture Association (sebastian belle)

6/08/20 @ 2:27 AM

June 7, 2020
Comments in SUPPORT of Cooke Aquaculture application to modify WA state NPDES permits.
The Maine Aquaculture Association (MAA) is the oldest state aquaculture association in the US. Our members grow finfish, shellfish and sea vegetables us...↓
Cooke Aquaculture was an early participant in the development of the MAA Code of Practice, MAA Biosecurity Management Program (BMP), and the MAA Containment Management System (CMS). Both the BMP and CMS were the first of their kind in the world and were developed in cooperation with several environmental groups and state and federal regulators. The MAA BMP and CMS have subsequently formed the basis for several the international sustainability certification programs and regulations in a number of other states and countries. Since that pioneering work, Cooke has continued their sustainability work and pursued certification under a number of these independent programs. For example: Cooke Aquaculture submitted its salmon farms to audits by independent, third-party certification bodies beginning in June 2011. By March 2015, Cooke Aquaculture had achieved four-star Best Aquaculture Practices (BAP) status, one of only three salmon-farming companies in the world to do so at the time. Four-star BAP status is the highest achievement in the BAP program, requiring a combination of the company's processing plants, farms, hatcheries and feed mills are BAP certified. BAP is the world's most comprehensive aquaculture certification program, with standards encompassing environmental responsibility, social accountability, animal health and welfare, and food safety. Processing plants, farms, hatcheries and feed mills must demonstrate 100 percent compliance to these standards in an annual audit to attain BAP certification.
Cooke Aquaculture has also made strides in greatly reducing the use of antibiotics, and in the development of nonchemical sea lice management methods. Several of its salmon hatcheries and farms were third party audited last year to verify that no antibiotics were used throughout the entire life cycle of those fish. This has not yet been achieved for all salmon produced by Cooke Aquaculture, but they are a clear leader in responsible use of therapeutants and novel animal health management methods. Another good example of Cooke's dedication to excellence, community and environmental sustainability is their upgrade by the Monterey Bay Aquarium Seafood Watch program.
It is unfortunate that the Cooke Aquaculture salmon farm in Washington suffered damage and fish escapes shortly after it was acquired and before the facility could undergo planned renovations. Cooke's track record here in Maine shows that they invest significantly to upgrade any operations they acquire. Often existing regulations or permit conditions unintentionally slow down their ability to upgrade a facility and innovate to more sustainable production methods. While there is no evidence of any lasting ecological impact of the fish that escaped from the farms in Washington state, the blanket prohibition of the culture of Atlantic Salmon in the state was clearly a political decision driven by emotion not by science. Ironically the prohibition of culturing a non-native finfish species is clearly inconsistent with state's policy of actively supporting the commercial culture of non-native shellfish species.
The Coller Fairr Protein Index, which ranks protein producers on material environmental, social and governance issues against the United Nations Sustainable Development Goals, ranks aquaculture at the top for sustainability. Some players in the global seafood arena have gone above and beyond the call of organizations like the United Nations, and Cooke Aquaculture is such a player. While half of all the seafood we eat in this country is farmed, the U.S., unfortunately, remains a comparatively minor aquaculture producer. This needs to change. The National Oceanic and Atmospheric Administration says, "aquaculture in the United States contributes to seafood supply, supports commercial fisheries, restores habitat and at-risk species, and maintains economic activity in coastal communities and at working waterfronts in every coastal state." Sustainable aquaculture growth can benefit not only economic and environmental health but public health as well. The U.S. Dietary Guidelines recommend Americas eat at least two to three servings of seafood per week, but we eat, on average, just one. A Harvard University study shows low seafood intake is responsible for 84,000 preventable deaths a year in this country. Positive nutrition outcomes coupled with economic and environmental benefits make aquaculture an important aspect of our food security. Aquaculture is a science-based business and relies on veterinarians, biologists and environmental scientists for advice and oversight of everyday farming practices.
The proposed amendments to Cooke's Washington state NPDES permits would allow Cooke to continue to operate and invest in renovated facilities and use sterile steelhead trout. This would allow Cooke to contribute to a domestic supply of healthy seafood and the strengthening the states working waterfronts. The use of sterile steelhead trout will have no impact on the level or nature of any nutrients released into the local environment. Washington state has done extensive research and monitoring of net pen operations in the state and the current regulations on any discharges from net pen operations are some of the strictest in the world. The proposed permit modification is required by those regulations and as such should be granted. Having read most of the comments submitted so far it is astounding the level of misunderstanding and intentionally inflammatory misinformation that is being allowed into the record. I strongly urge the agency to view these comments for what they are and to discount them as nothing more than scare tactics designed to politically pressure the agency. I strongly support the proposed permit amendments and encourage the agency to make its decision based on science not emotion or political pressures from special interest groups who push the "send button" on e mail campaigns designed to support their fundraising efforts.
I would be glad to answer any questions the agency has with respect to Cooke's long track record of environmental leadership here in Maine.

Respectfully Submitted
Sebastian Belle
Executive Director
Maine Aquaculture Association
Hallowell Maine

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Comment From: Mary Rawlins

6/08/20 @ 2:23 AM
Re: Cooke application to permit modification to raise Steelhead

Thank you for taking comments. Cooke Aquaculture Pacific has a poor track record here in Puget Sound. They are now rushing to do this species change in order to use the net pens they ha...↓

'HB 2957's new standards require re-examining past decisions to hold Cooke Aquaculture to that higher standard of eliminating these risks.

In reviewing Cooke's submissions and other materials submitted through this public process, the standard of review should be specifically on whether the policies in place achieve the state's goal to "eliminate...escapement and to eliminate negative impacts to water quality and native fish, shellfish, and wildlife." Please deny the permit application. Thank you.
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Comment From: Suzanne Gray

6/08/20 @ 2:17 AM
Cooke Aquaculture has routinely shown their inability to protect the health and safety of the Salish Sea and the inhabitants of it. The NPDES permit they seek for steelhead farming in the Salish Sea should not be granted while the courts are still re...↓
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Comment From: Inderjit Bains

6/08/20 @ 1:52 AM
I support the farming of sterile
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Comment From: Tony Fallow

6/08/20 @ 1:45 AM
These farms are destroying our wild runs of fish with disease! Do not allow them to operate!
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Comment From: Rebecca Moore

6/08/20 @ 1:40 AM
I am very concerned about fish farms, no matter what species of fish are being raised. While in theory they may seem to be a good idea (raise fish for growing markets) the advantages do not seem commensurate with the risks they pose to wild fish spec...↓
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Comment From: Karin Wiley

6/08/20 @ 1:36 AM
I think that this is good for everyone. The numbers of wild fish are not as great as they used to be and to keep up with the demand of the consumers that enjoy them we need to support this application.
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Comment From: Richard Butt

6/08/20 @ 1:18 AM
I support this.
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Comment From: Anonymous Anonymous

6/08/20 @ 1:09 AM
That the lease site switch from Atlantic salmon to sterile native rainbow trout is not automatic for the Department of Ecology is ridiculous. The time and wasted tax dollars engaging in this comment process wastes valuable WA food production capacity...↓
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Comment From: matthew nelson

6/08/20 @ 1:05 AM
Considerations that need to be addresssed should include: I have concerns about 1) bio-engineered and/or GMO-containing food for these captive fish being introduced into the natural ecosystem. 2) The waste produced by un-eaten food, as well as the ...↓
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Comment From: ACFFA (ACFFA ACFFA)

6/08/20 @ 12:58 AM
In an era when traditional fishing opportunities and access to arable land are declining, fish farming has become critical to world food security. Aquaculture is science based. Fish farmers work with the best researchers from governments, universitie...↓
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Comment From: Christopher Webb

6/08/20 @ 12:09 AM
I strongly believe that aquaculture is an important part of food production, that can be achieved in a sustainable manner.

Having worked in the Aquaculture industry for a number of years in the UK, I have seen first hand the positive benefits this bri...↓

As such I very much support Cooke Aquacuture, in their application to Washington State, to amend their permit to produce triploid Steelhead Trout.

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Comment From: Christopher Webb

6/07/20 @ 11:56 PM
I strongly believe that aquaculture is an important part of food production, that can be achieved in a sustainable manner.

Having worked in the Aquaculture industry for a number of years in the UK, I have seen first hand the positive benefits this bri...↓

As such I very much support Cooke Aquacuture, in their application to Washington State, to amend their permit to produce triploid Steelhead Trout.

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Comment From: Christopher Edwards

6/07/20 @ 5:12 PM
Simply changing the species of fish raised does not resolve the pollution and disease threats posed by net pens. The only real way to eliminate those threats is a total ban.
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Comment From: Siri Love

6/07/20 @ 4:15 PM
I am strongly opposed. The well-documented risks outweigh the little benefit Cooke offers this community.
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Comment From: Mark Stevenson

6/07/20 @ 2:58 PM
We believe Cooke's change of fish species in their application does not eliminate the risks of pollution of the natural environment. A plume of degraded water quality around the pens is to be expected. Cooke's history with open water net pens is not...↓
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Comment From: Martin Lindenmeyer

6/07/20 @ 2:16 PM
Allowing Cooke Aquaculture to have a second chance after clear negligence in their prior operation in the Puget Sound is irresponsible. Triploid trout are genetically altered and not native to this region. This is no different than intentionally intr...↓
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Comment From: Coleman Byrnes

6/07/20 @ 2:16 PM
Net pen aquaculture is a polluting industry. We are, hopefully, trying to make the Salish Sea cleaner and this type of aquaculture works against this goals. Diseases spread in crowded conditions. Net pens are crowded. Diseases in farmed steelhead cou...↓
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Comment From: ROBERT IWAMOTO

6/07/20 @ 1:48 PM
I am a retired NOAA fisheries scientist with a PhD in fisheries genetics from the University of Washington. During my career with NOAA and the academic and private sectors, I have been involved with many of the key scientific issues and questions th...↓

Having evaluated the scientific evidence, I can unequivocally state that the benefits of Cooke Aquaculture's petition far outweigh any possible negative outcomes. With the current permitting regulations and best management practices, the possibility of large-scale losses and escapes should be minimized. Furthermore, the use of triploidized fish that are derived from highly domesticated strains should drive the odds of possible competition and interbreeding with local populations even closer to zero due to inherent reproduction- and fitness-related barriers.

I fully support Cooke Aquaculture's permit modification. I believe that the possible negative effects of Cooke Aquaculture's plans with steelhead farming are extremely over-stated and that the science underlying their request should determine the final decision.

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Comment From: Stephen Weatherford

6/07/20 @ 12:41 PM
I fully support Cooke Aquaculture in their continued effort to bring the world fresh and healthy farm raised fish. The proposed sterile all female triploids will thrive here in their native environment.
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Comment From: Justin Boucher

6/07/20 @ 12:27 PM
I write to you regarding Cooke Aquaculture's application to "produce" steelhead in net pens:

1) Ecology should not authorize Cooke's modified NPDES permits until the ongoing lawsuit challenging the State Environmental Policy Act (SEPA) environmental r...↓

2) There is substantial new information that was not considered during the SEPA process.

The SEPA determination issued in January, 2020 (Mitigated Determination of Nonsignificance (MDNS), requires Cooke to prepare and submit a plan for marking steelhead (clipping the adipose fin) in ways that will distinguish fish from their pens from hatchery-raised fish swimming freely in Puget Sound. That plan is not part of this record, and review of the NPDES permit application should await that filing.

The MDNS also requires Cooke to submit a plan for a "no-recovery response" to escapes. That plan is not part of the escape plan submitted in Cooke's application, and it is impossible to assess the adequacy of Cooke's pollution prevention plan until that plan is included in the application.

During the emergency response to the Orchard Rocks partial sinking, Cooke told DNR that they planned to replace some existing net pens in Puget Sound. If indeed that plan is under way, the NPDES review should include engineering data on the new pen structures in order to assess the adequacy of those pens for Puget Sound's dynamic conditions, and the escape risk and other risks the new pens might pose to Puget Sound.

The SEPA review led by the Washington Department of Fish and Wlidlife which produced the MDNS, is currently being appealed (see #1). Given the potential for a Court ruling requiring additional environmental review under SEPA and this new information described above, Ecology should delay drafting any NPDES permit until the evidentiary record and ruling can be incorporated.

3) Ensuring compliance of rules set by NPDES permits is crucial.

Cooke's history of CWA violations is important to consider in this process, if nothing else to ensure that the permits are drafted to ensure that violations are detected before catastrophe ensues.

Incidents like the partial sinking of the Orchard Rocks pen in October, 2019 demonstrate that the risks of additional escapes are very real, given the state of the existing pen structures. The response to that incident was conducted by several Washington State agencies, including Ecology, and the records from that incident and state agencies' documentation of Cooke's inadequate emergency response should be included in this record to ensure that emergency plans incorporate lessons learned, and acknowledge the degraded state of the surviving pens as identified by state inspectors and Cooke's own contractors.

4) Washington's landmark 2018 law, HB2957, created a new and stricter regulatory regime for marine net pen aquaculture.

In 2018, Washington's passed a law, HB 2957, banning Atlantic salmon net pens on the grounds that the practice placed too great a risk on the ecosystem, created a new and stricter regulatory regime for marine net pen aquaculture.

As such, it is not sufficient to say that conditions of the current NPDES application are similar to those of past permits. HB 2957's new standards require re-examining past decisions to hold Cooke Aquaculture to that higher standard of eliminating these risks.

In reviewing Cooke's submissions and other materials submitted through this public process, the standard of review should be specifically on whether the policies in place achieve the state's goal to "eliminate...escapement and to eliminate negative impacts to water quality and native fish, shellfish, and wildlife."

5) Switching species does NOT reduce the rampant daily pollution and water quality risks posed by open water net pen aquaculture. Ecology should not limit the scope of their review to risks associated with a change of species.

Decades of experience shows real effects on water quality in a plume around the net pens, which the terms of Cooke's current permit application does not eliminate. This NPDES review should re-examine existing data on effluents from industrial products, medicines, feed, fish waste, and dead and rotting fish to assess whether the current plans eliminate all of those risks.

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Comment From: Justin Boucher

6/07/20 @ 12:07 PM
I write to you regarding Cooke Aquaculture's application to "produce" steelhead in net pens:

1) Ecology should not authorize Cooke's modified NPDES permits until the ongoing lawsuit challenging the State Environmental Policy Act (SEPA) environmental r...↓

2) There is substantial new information that was not considered during the SEPA process.

The SEPA determination issued in January, 2020 (Mitigated Determination of Nonsignificance (MDNS), requires Cooke to prepare and submit a plan for marking steelhead (clipping the adipose fin) in ways that will distinguish fish from their pens from hatchery-raised fish swimming freely in Puget Sound. That plan is not part of this record, and review of the NPDES permit application should await that filing.

The MDNS also requires Cooke to submit a plan for a "no-recovery response" to escapes. That plan is not part of the escape plan submitted in Cooke's application, and it is impossible to assess the adequacy of Cooke's pollution prevention plan until that plan is included in the application.

During the emergency response to the Orchard Rocks partial sinking, Cooke told DNR that they planned to replace some existing net pens in Puget Sound. If indeed that plan is under way, the NPDES review should include engineering data on the new pen structures in order to assess the adequacy of those pens for Puget Sound's dynamic conditions, and the escape risk and other risks the new pens might pose to Puget Sound.

The SEPA review led by the Washington Department of Fish and Wlidlife which produced the MDNS, is currently being appealed (see #1). Given the potential for a Court ruling requiring additional environmental review under SEPA and this new information described above, Ecology should delay drafting any NPDES permit until the evidentiary record and ruling can be incorporated.

3) Ensuring compliance of rules set by NPDES permits is crucial.

Cooke's history of CWA violations is important to consider in this process, if nothing else to ensure that the permits are drafted to ensure that violations are detected before catastrophe ensues.

Incidents like the partial sinking of the Orchard Rocks pen in October, 2019 demonstrate that the risks of additional escapes are very real, given the state of the existing pen structures. The response to that incident was conducted by several Washington State agencies, including Ecology, and the records from that incident and state agencies' documentation of Cooke's inadequate emergency response should be included in this record to ensure that emergency plans incorporate lessons learned, and acknowledge the degraded state of the surviving pens as identified by state inspectors and Cooke's own contractors.

4) Washington's landmark 2018 law, HB2957, created a new and stricter regulatory regime for marine net pen aquaculture.

In 2018, Washington's passed a law, HB 2957, banning Atlantic salmon net pens on the grounds that the practice placed too great a risk on the ecosystem, created a new and stricter regulatory regime for marine net pen aquaculture.

As such, it is not sufficient to say that conditions of the current NPDES application are similar to those of past permits. HB 2957's new standards require re-examining past decisions to hold Cooke Aquaculture to that higher standard of eliminating these risks.

In reviewing Cooke's submissions and other materials submitted through this public process, the standard of review should be specifically on whether the policies in place achieve the state's goal to "eliminate...escapement and to eliminate negative impacts to water quality and native fish, shellfish, and wildlife."

5) Switching species does NOT reduce the rampant daily pollution and water quality risks posed by open water net pen aquaculture. Ecology should not limit the scope of their review to risks associated with a change of species.

Decades of experience shows real effects on water quality in a plume around the net pens, which the terms of Cooke's current permit application does not eliminate. This NPDES review should re-examine existing data on effluents from industrial products, medicines, feed, fish waste, and dead and rotting fish to assess whether the current plans eliminate all of those risks.

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Comment From: Walton Dickhoff

6/07/20 @ 10:40 AM
• I write in support of Cooke Aquaculture's application to culture steelhead in net pens in Puget Sound. I am a retired Professor of Fisheries at University of Washington and retired Senior Scientist at NOAA Fisheries National Marine Fisheries Servic...↓

The methods and procedures that Cooke Aquaculture uses for steelhead rearing leave almost no risk to native salmon stocks. It is well established that rearing steelhead for only one generation in a hatchery reduces the majority of their fitness to survive in the wild. Cooke's steelhead stocks have been reared in captivity for tens of generations. Furthermore, the high rates of sterilization (99%+) using triploidy make it extremely unlikely that any escaped fish would survive to spawn in streams in the Salish Sea.

The risk of disease or parasite spread from cultured to wild fish is minimal. Steelhead that will be put into net pens are monitored for disease/infection before they are transferred. If an outbreak of disease occurs subsequently (due to infection from wild fish), the net pen fish are quickly harvested to reduce risk. Sea lice infections are only a problem in certain areas of the Salish Sea in Canada. I have reared tens of thousands of salmon in net pens for research in Puget Sound over 20 years and have not seen a single sea lice infection.

Concern about pollution from net pens is overstated considering current guidelines for siting. Adequate tidal exchange and depth requirements along with fallowing minimize impacts on water and seabed quality. Impacts of net pens on water quality are only detectable within 30 yards of the pens.

I fully support approval of Cooke's application. Net pen salmon culture is a safe and sustainable local source of quality seafood. Thank you for the opportunity for public comment.

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Comment From: Tom Hansen

6/07/20 @ 10:40 AM
Thank you for allowing public comment on this very important environmental issue. My comments are in the attached file.
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Comment From: Ben Ward

6/07/20 @ 10:05 AM
To Comment Letter

To whom it may concern,

I am writing to you today to express my concerns relating to the proposal to allow Cooke Aquaculture to raise steelhead in these fisheries. I first want to address that I am not a current resident of Washington...↓

That is why I am writing to you to say I do not approve of Cooke Aquaculture raising Steelhead in these fisheries. Cooke has shown on multiple occasions that they as a company do not care about the safety of the environment. Be it the placement of their pens in ecosystems that are actively used by endangered species, or the use antibiotic feed and chemicals which can then spread and harm the native flora, or the repeated failures of their pens releasing non-native species into your very watersheds, and last the blatant disregard for the law in relation to the placement of pens on Indian Tribal lands. I understand the importance of aquaculture and the money it brings in, but it has to be done ethically and in a way that protects our environment. Something that Cooke clearly does not care about.

Salmon and Steelhead are under tremendous pressure and an unprecedented decline in your state. That is something that worries me as someone who desperately wants to spend time and money in your state trying to catch these amazing animals. The outdoor industry here in Colorado produces an estimated $28 billion in consumer spending and an estimated $2 billion in direct state and local revenue. It is threats like that of Cooke that directly impact the long term future of the outdoor economy. Imagine the impacts of losing an economy of that size and scale, because in the long term it is actions like allowing Cooke to place these farms that will lead to the demise of the outdoor economy.

In summary I urge you as someone who wants to spend time and potentially move to your great state to not allow Cooke to raise steelhead in these fisheries. The risks are too great for declining steelhead and salmon. Cooke has shown that they care more about a quick buck and paying fines than they do about the long term health of the environment and the economy it creates. Thank you for your time.

Sincerely,
Ben Ward
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Comment From: Paul Allen

6/07/20 @ 9:34 AM
Re: Cooke Aquaculture Pacific NPDES permit applications to raise steelhead

I am very concerned about potential problems with the Cooke Aquaculture operation and the results of a concentrated industrial fish operation.
The major concerns I have are the ...↓
I also am concerned about the use of antibiotics and, or treatments used to treat likely concentration of fish parasites, which would not be introduced into this habitat but for the Cooke Aquaculture operation.

Sincerely,
Paul Allen
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Comment From: judy english

6/07/20 @ 9:23 AM
Open water net pen aquaculture by Cooke needs very careful thought and discussion. Maintaining the healthy ecology of Puget Sound waters, of native species and of native habit is essential. We humans have often made ecological decisions that were qu...↓

Under consideration should be fish effluent, fish waste, medicines and food particles, the fish themselves,, etc that escape from pen netting and flow around the Sound's aquatic environment.

Cooke already has a poor past record of caring for their open water net pen aquaculture. They have shown poor oversite by themselves and they should not be applying for another permit until the one they have is completed especially since they want to switch their fish product which was not indicated in their first contract.

Please, please be slow and careful with your decisions. Thank you.
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Comment From: Joe Bragan

6/07/20 @ 9:14 AM
Puget Sound is a beautiful natural ecosystem. Cooke aquaculture has consistently damaged fragile marine environments through aquaculture. Disease, fish waste and escaped fish have had major impacts throughout Canada. Chemicals and antibiotics are...↓

I visit Washington as a tourist yearly and do so because of the natural environment. The damage open net pens will have in the local marine environment is in most cases irreparable.

Cooke has paid out more than $10,000,000 in fines and have 21 violations most of which are environmental.

Protect the most important resource you have.

Best,

Joe Bragan
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Comment From: ERIC RUNNING

6/07/20 @ 8:21 AM
I am opposed to the permit modification allowing Cooke Aquaculture to transition from farming Atlantic Salmon to triploid Steelhead at its existing net pen facilities in Washington State waters. Cooke Aquaculture has demonstrated an inability to main...↓

The fact is that no precedent exists for large scale farming of triploid Steelhead in a marine environment. Permitting Cooke Aquaculture to undertake such an effort would be to entrust a company with a troubled compliance record to carry out a large scale experiment in Washington's precious marine environment, with potentially serious consequences for the health of the ecosystem of the Salish Sea. The permit should be denied, and Cooke should end its current Atlantic Salmon farming operations as scheduled as provided for in State law.
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