Rulemaking - Outstanding Resource Waters, Chapter 173-201A WAC

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Comment From: Marsha Adams

9/26/23 @ 12:00 AM

"Dear Washington Department of Ecology, Washington’s rivers, streams, and wetlands supply drinking water to residents across the state, sustain wildlife habitat, and provide an economic boost to local communities. As a Washingtonian, I want to see th...↓

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Comment From: Patti Rader

9/26/23 @ 12:00 AM

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Comment From: Ra'id Khalil

9/26/23 @ 12:00 AM

I am writing today in support of the proposed rulemaking to designate parts of the Cascade, Green, and Napeequa River systems as Outstanding Resource Waters (ORW).

As Washington State grapples with a booming population, the plight of our endangered s...↓

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Comment From: Christopher Mahannah

9/26/23 @ 12:00 AM

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Comment From: Nabor Navarro

9/26/23 @ 12:00 AM

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Comment From: Fritz Wollett

9/26/23 @ 12:00 AM

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Comment From: Bee Evans

9/26/23 @ 12:00 AM

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Comment From: Kathy Wilson

9/26/23 @ 12:00 AM

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Comment From: Kristin Serniotti

9/26/23 @ 12:00 AM

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Comment From: Alexzandra Thal

9/26/23 @ 12:00 AM

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Comment From: Levi Saiwz

9/26/23 @ 12:00 AM

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Comment From: Zach Zuniga

9/26/23 @ 12:00 AM

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Comment From: Paula O'Brien

9/26/23 @ 12:00 AM

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Comment From: Denise Rodiscuz

9/26/23 @ 12:00 AM

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Comment From: Sue Juhre

9/26/23 @ 12:00 AM

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Comment From: Martha Atkinson

9/26/23 @ 12:00 AM

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Comment From: Frank Stieber

9/26/23 @ 12:00 AM

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Comment From: Peter Murphy

9/26/23 @ 12:00 AM

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Comment From: Katarina Dick

9/26/23 @ 12:00 AM

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Comment From: Caitlin Singer

9/26/23 @ 12:00 AM

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Comment From: Jennifer Clark

9/26/23 @ 12:00 AM

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Comment From: Travis Bass

9/26/23 @ 12:00 AM

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Comment From: Olivia Castillo

9/26/23 @ 12:00 AM

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Comment From: Marisa Lord

9/26/23 @ 12:00 AM

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Comment From: Vanessa Lee

9/26/23 @ 12:00 AM

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Comment From: AnnaMarie McConnor

9/26/23 @ 12:00 AM

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Comment From: Jason Williams

9/26/23 @ 12:00 AM

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Comment From: Cheri Carlson

9/26/23 @ 12:00 AM

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Comment From: Kelsey Cross

9/26/23 @ 12:00 AM

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Comment From: Bill Burgess

9/26/23 @ 12:00 AM

Letter postmarked on Sept. 26, 2023.

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Comment From: Howard Wilson

9/25/23 @ 10:45 PM

I have rivers and streams all over my forest land. please allow me to grow trees.

Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. ...↓

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Comment From: TED HOGEWEIDE

9/25/23 @ 10:37 PM

Please postpone any designations of Tier III waters.

1)Until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be availabl...↓e so we can have both meaningful public participation and transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

2)Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.

3)Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.

4)Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.

5)Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Dylan Worlock

9/25/23 @ 10:34 PM

Please do not enact the rule allowing designation of type 3 waters without transparent reasoning and input from the public and other experts.

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Comment From: Jessica Mitchell

9/25/23 @ 9:57 PM

I am opposed to new rule-making based on the lack of information provided to the public as to what these rules will be, what specific problem(s) these rules will be designed to solve, and how the success of the problem-solving will be measured. The D...↓

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Comment From: Judith Akins

9/25/23 @ 8:51 PM

I am writing in support of designating the Cascade River as an Outstanding Water Resource (ORV) pursuant to WAC 173-201A-330. I have lived in this area for over a decade and have come to love the natural beauty of this unique place in western WA. We ...↓

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Comment From: Stacy Lee King

9/25/23 @ 7:44 PM

I am writing in support of the proposed Outstanding Resource Water designation for Soap Lake. My father's family were itinerant farmers in Eastern Washington and he was born at the Soap Lake hospital, so my family has been aware of this unique place ...↓

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Comment From: Jan Devnich

9/25/23 @ 6:48 PM

No designation of type111 water without transparency to voters.

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Comment From: Tom Westergreen

9/25/23 @ 6:37 PM

I strongly disagree with DOE considering all of the proposed outstanding resources waters and the Cascade River in particular. DOE maps for this designation were extremely hard to interpret and seems like information is being hidden. Our state regul...↓

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Comment From: Richard Bowers

9/25/23 @ 5:54 PM

I am writing in support of the proposed rulemaking to establish the first of Washington's Tier III (A) Outstanding Water Resources (ORV) pursuant to WAC 173-201A-330. I urge the Department to provide needed state protections to approximately one-hund...↓

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Comment From: Gayle Thompson

9/25/23 @ 5:44 PM

Please postpone any action on this. Do not take our ability to be in nature. We are good stewards of the earth

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Comment From: Blade Fry

9/25/23 @ 5:21 PM

Dear Ms Koberstein

Please stop the government overreach on expanding type III water designations without first thoroughly vetting the costs and benefits. The rush to “protect” often has the opposite effect in total.

Thank you

Blayde Fry

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Comment From: Eric Rohrbach

9/25/23 @ 5:20 PM

Please postpone any designations of Tier III waters until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available so...↓

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Comment From: Saxton's Timber Farm and Sanct... (Darrell Saxton)

9/25/23 @ 5:16 PM

Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a prec...↓

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Comment From: Norman Oliver

9/25/23 @ 4:41 PM

This seems a little like a surprise to many people. Please make no rule changes until your governing board has presented a comprehensive environmental report so that everyone has had a chance to review it!
Thank you.

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Comment From: Laurel Black

9/25/23 @ 4:39 PM

Rulemaking for designating Type III waters needs to be halted until all environmental impacts of these designations have been identified and disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and s...↓

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Comment From: Andrea Xaver

9/25/23 @ 4:18 PM

I’ve not heard of this specific issue before. I’m concerned about all waters. I agree that more transparency is needed, and more time for consideration; and cause and effects re certain areas.

Andrea Xaver

Dancer@fidalgo.net

360-202-9533

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Comment From: Joseph Murray

9/25/23 @ 4:07 PM

Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges...↓

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Comment From: State Senator (Keith Wagoner)

9/25/23 @ 3:59 PM

As the elected Senator for this area, I am opposed to ANY further restrictions on our communities ability to enjoy and utilize the natural resources in our own backyards. I made this clear when the petitioners first brought this idea forward. Skagi...↓

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Comment From: Kent Turner

9/25/23 @ 3:49 PM

I support designation of Cascade River as an Outstanding Resource Water. It is virtually undisturbed and of high natural and scenic resource value.

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Comment From: Dee Hammons

9/25/23 @ 3:44 PM

I'd like full disclosure about designation of type III on Washington's waters: rivers, lakes, ocean, streams. If these are public lands, we have a right to know.

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Comment From: Bruce Bare

9/25/23 @ 3:31 PM

Until clear transparency has been demonstrated and the costs and benefits of the proposed action have been provided, any new designations for Type III waters should be postponed.

Presently, there is a lack of sufficient water quality data to suppor...↓

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Comment From: Robert Keller

9/25/23 @ 3:24 PM

NO designation of Type III waters without full transparency concerning the impacts.

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Comment From: Brian Ballard

9/25/23 @ 3:23 PM

Please postpone any designations of Tier III waters.

Until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available ...↓so we can have both meaningful public participation and transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.

Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.

Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.

Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.

This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.

Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities. Thank you.

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Comment From: Washington Native Plant Societ... (Denise Mahnke)

9/25/23 @ 3:19 PM

Thank you for considering the comment letter provided by the Washington Native Plant Society Conservation Committee, and State Board of Directors, in response to Rulemaking - Outstanding Resource Waters, Chapter 173-201A WAC comment period.

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Comment From: LEO Finnegan

9/25/23 @ 3:14 PM

The Department is in the process of classifying some water as Type III. The Department has not given the affected communities an opportunity to comment on this action. The SEPA submitted is incomplete.
I urge the Department to allow the communities t...↓

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Comment From: Chris Humann

9/25/23 @ 2:47 PM

You need to be transparent about designating any waters as type 3. Do not designate them without consulting private landowners and communities that would actually be impacted.

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Comment From: Robert Smithing

9/25/23 @ 2:44 PM

Until clear transparency has been met, we urge that Ecology pause the rulemaking process. Given that this is the first time Ecology is designating these waters, a very high standard and clear and specific information should be available to have both ...↓

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Comment From: Cheryl Simmons

9/25/23 @ 2:44 PM

I am in support of adding all of the proposed bodies of water to the Tier III designation. Do not cave to industry who look at the shortsighted view of maximizing profit. We must protect these water bodies for future generations.

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Comment From: Assoc. of Consulting Foresters Anonymous

9/25/23 @ 2:39 PM

The current rules regarding waters of Washington are adequate for protecting our waters. Before any designation of Type III waters a full accounting of impacts to forest management activities must be made. Just be transparent with all issues. Large a...↓

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Comment From: Michael Jackson

9/25/23 @ 2:30 PM

There should be no designation of Type III waters without full transparency concerning the impacts they have to forest management in our state.

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Comment From: Doug Stienbarger

9/25/23 @ 2:21 PM

Please postpone Tier III designations.

You need more transparency, given that this is the first time you are designating these waters. There should be a standard, clear, and specific process available to allow meaningful public participation and tr...↓ansparent analysis. You have not shown sufficient water quality data to support either designations or benefits for your proposal. There appear to be significant economic impacts, and you do not make clear the environmental impact on land and shoreline use. The potential restriction of human activities without adequate public and legislative approval troubles me. I urge DOE to pause the rulemaking, while you conduct a thorough and transparent analysis of site-specific data, and consider public input to outline benefits as well as costs.

Your lack of transparency makes it difficult for others to verify and validate your conclusions. It also increases public mistrust in the scientific basis of your proposal and leads to sinister implictions aboutt impacts on communities.

You fail to adequately demonstrate the added benefit you claim for this designation. To what degree and how much will this designation surpass current DOE water quality standards and their impacts on water quality, recreation, and fish and wildlife populations?

You do not articulate specific economic impacts, nor how you arrive at those impacts. This includes: economic impacts on adjacent communities; the scope of areas proteced (size annd location); specific BMPs and their cost. Your lack of specificity significantly undermines your proposal and makes verification difficult.

Your proposal fails to identify either good or bad environmental impacts, even though your proposal will clearly preclude roads and public access, as well as impact forest management, especially for wildfires.

You fail to quantitativly identify both the need for Tier III designation and the cost of designation. Your proposal therefore appears vague and subjective.

DOE's expansion of Tier III designations will prevent activity in large sections of the state's watersheds without adequately articulating how you arrived at your proposal.

As my math and science teachers always told me, "show your work". Without the ability to verify and validate, you subject your agency to claims of overreach and implications of sinister intentions. Clearly show me and other citizens why we should give up what you ask for.

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Comment From: Brian Saltvick

9/25/23 @ 1:46 PM

Please postpone any designations of Tier III waters.

Until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available ...↓so we can have both meaningful public participation and transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Double O Ranch (Cindy Kleinhuizen)

9/25/23 @ 1:41 PM

Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would signific...↓

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Comment From: Michael Saltvick

9/25/23 @ 1:41 PM

NO designation of Type III waters without full transparency concerning the impacts.

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Comment From: Ken and Bonnie Miller

9/25/23 @ 1:18 PM

* this is a very serious/significant step that needs far more public disclose before decisions are made.

* it's not widely known but over 50% of our states 22 million acres are already in no-touch/no-management status;

* the scientific community is...↓

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Comment From: Traci Lund

9/25/23 @ 1:03 PM

Please postpone any designations of Tier III waters. Since this is the first time Ecology is designating these waters, a very high standard and clear and specific information should be available for meaningful public participation and transparent ana...↓

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Comment From: BJ Leggett

9/25/23 @ 12:56 PM

Please postpone any designations of Tier III waters.

Until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available ...↓so we can have both meaningful public participation and transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Julie Nyborg

9/25/23 @ 12:47 PM

Until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available so we can have both meaningful public participation an...↓d transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Skagit County Farm Bureau (William Schmidt)

9/25/23 @ 12:45 PM

This major change in water reclassification needs a full analysis of scientific data to show the need for the change; impacts to farms, ranches, forest practices and private property; all the costs to implement, monitor, enforce and economic hardship...↓

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Comment From: Christine Mallon

9/25/23 @ 12:33 PM

Stop the more restrictive regulations affecting small private forest landowners like me.

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Comment From: Mary Knight

9/25/23 @ 12:20 PM

Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded...↓

No attachments

Comment From: Nancy Button

9/25/23 @ 12:02 PM

It has come to my attention that the Department of Ecology is attempting to change the designation of waters in Washington State. I strongly object to this designation of Type III waters without full transparency to the public concerning the impacts....↓
Please postpone any designations of Tier III waters until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available so we can have both meaningful public participation and transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Elizabeth Knudsen

9/25/23 @ 11:54 AM

Please postpone any designations of Tier III waters.

Until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available ...↓so we can have both meaningful public participation and transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Patricia Lee Witter

9/25/23 @ 11:52 AM

Please delay designation of Tier III waters until transparency and public input can be appropriately considered.

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Comment From: James Miller

9/25/23 @ 11:43 AM

Please postpone any designations of Tier III waters.

Until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available ...↓so we can have both meaningful public participation and transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Richard Hanson

9/25/23 @ 11:39 AM

Please postpone any designations of Tier III waters.

Until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available ...↓so we can have both meaningful public participation and transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Lisa Sudar

9/25/23 @ 11:37 AM

I am writing to comment on the designations of Tier III waters. I am surprised by this move by Ecology because it seems like it is outside their normal scope. I'm also dismayed that there is no transparency here. Why are they choosing this action? Ha...↓

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Comment From: Scott Grigg

9/25/23 @ 11:36 AM

We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to de...↓

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Comment From: juli cannon

9/25/23 @ 11:35 AM

NO designation of Type III waters without full transparency concerning the impacts.

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Comment From: Mike Woods

9/25/23 @ 11:26 AM

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Comment From: Cheryl Woods

9/25/23 @ 11:25 AM

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Comment From: Donald Frey

9/25/23 @ 11:17 AM

Please postpone any designations of Tier III waters.

Until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available ...↓so we can have both meaningful public participation and transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: John Roscoe

9/25/23 @ 11:16 AM

You are way, way over the line to designate any Type 3 areas in our state. This proposal is a great example of Ecology imposing the views of a tiny group of environmental extremists on all Washingtonians without a shred of evidence to support it

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Comment From: Darcy MacPherson

9/25/23 @ 11:14 AM

Ecology is not being transparent. Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit. We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs. Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology’s Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad. Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology’s action would be unprecedented and poorly defined. This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology’s recent history of misapplying regulatory standards casts a shadow over this new action. Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.
What the proposed practices? Do they need to be revised? I don’t see any references to native American involvement.

Regards

Darcy J MacPherson↓

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Comment From: Underwood Ranch LLC (Kurt Underwood)

9/25/23 @ 11:10 AM

Please postpone any designations of Tier III waters, until a more thorough analysis is shared with public and legislature.

Until clear transparency has been sufficiently provided to the public, this could create significant financial harm to busines...↓ses, individuals, and timber tax revenues that fund programs in the State of WA. Given that this is the first time ever that Ecology has elevated a proposal for designating these waters, a clearer standard and more data on specific objectives should be available so the public can evaluate with meaningful public participation and transparent analysis. At this point in time, there is a lack of sufficient data to support the designations and the benefits of this proposal. There could be significant economic harm and financial liabilities created by the hasty actions of Department of Ecology that would encumber the State of Washington with unwanted lawsuits. The environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is alarming. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Mark Kollasch

9/25/23 @ 11:09 AM

What are you doing and why? Be sure the public is completely aware and buys into your initiatives. We don't need government without representation...same as taxes without representation! What are the benefits and risks when you designate Type ...↓

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Comment From: Jason Hennig

9/25/23 @ 11:07 AM

Please postpone any designations of Tier III waters.
Until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available s...↓o we can have both meaningful public participation and transparent analysis. Right now there is a lack of sufficient water quality data to support the designations and the benefits of this proposal are unclear since many of the waters already have protection. There will be significant economic impacts, the environmental impact on land and shoreline use is undisclosed, and the potential restriction of human activities without adequate public and legislative approval is troubling. We urge the Department of Ecology to pause the rulemaking, conduct a thorough and transparent analysis of site-specific data, and consider public input to ensure benefits outweigh costs and regain public confidence in the rule-making process.
Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Glen Wood

9/25/23 @ 11:04 AM

Ecology is not being transparent.
Please pause this proposed rulemaking until transparent, objective, and robust analysis is conducted. Ecology should not designate these waters without giving the public clear and direct information about how it is ...↓making these designations, the costs of designation, and the implications for local communities.
Ecology has not demonstrated a clear benefit.
We encourage you to stop this rulemaking as Ecology has not identified a quantitative benefit for designating the waters. Ecology water quality standards are purportedly already being met in these waters although there is no site-specific data to demonstrate it. In any case, they are already subject to state and federal protection. Ecology's Preliminary Regulatory Analyses could not quantify the degree to which designation would improve water quality, increase recreational visits, or increase fish and wildlife populations.
Ecology has not revealed economic costs.
Please halt this rulemaking until Ecology has established a high standard for designations which will have significant economic impacts that have not been disclosed. Ecology's Tier III rulemaking acknowledges that Tier III designation would significantly impact current and future human activities adjacent to protected waters in public spaces, potentially preventing public use and access for recreation or other uses. Ecology also acknowledges that Tier III protection potentially has major implications on the economies of the state, acknowledging that designation will prevent large-scale development and may increase costs for small-scale development. But Ecology's Regulatory Analyses does not discuss economic impacts on adjacent communities of permanent protection. It does not acknowledge the square miles affected. Ecology will require activities to use "all applicable structural and nonstructural best management practices," but has not identified what those are or what they will cost.
Ecology has not disclosed environmental impacts – good or bad.
Please wait on the rulemaking until the environmental impacts of these designations are disclosed. Ecology is required by the State Environmental Policy Act (SEPA) to disclose impacts on land and shoreline use. Yet its SEPA decision does not acknowledge that the designation would likely prevent roads and public access for human activities adjacent to these waters. It also does not discuss potential impacts on forest management practices to prevent or fight catastrophic wildfires.
Ecology's action would be unprecedented and poorly defined.
This is the first time Ecology has designated waters since its rules were adopted 20 years ago. Failure here to identify a quantitative need and identify the cost of designation sets a precedent for overreaching in other waters. This is mainly a concern because Ecology's standards for designating waters as Tier III are vague and subjective.
Ecology's recent history of misapplying regulatory standards casts a shadow over this new action.
Ecology has recently been misusing its "Tier II" regulation to prevent measurable change in waters that are meeting state standards. Ecology's expanded use of Tier III designations could essentially prevent human activity in large portions of the state from headwaters to the ocean without any express approval by the Legislature, demonstrable benefit for water quality, and demonstrated support in affected communities.

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Comment From: Jonathan Morris

9/25/23 @ 11:03 AM

Please expand the type of waters designated as "Type III". We need to protect all our waterways.

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Comment From: L. H.

9/25/23 @ 10:57 AM

I support Ecology's multiple Tier III water designations.

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Comment From: Wally Bubelis

9/25/23 @ 10:56 AM

Citizens need to know what the benefits are in terms of economic and ecologic tradeoffs. I hope you will be more transparent about how this rule will help or harm communities.

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Comment From: Mike Leavitt

9/25/23 @ 10:48 AM

As I have read through the EPA definition of Tier III waters it seems Ecology is bastardizing the definition in order to designate waters and bypass the legislature. Please postpone any designations of Tier III waters until clear transparency has bee...↓

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Comment From: O'Neill Pine Company (Richard Pine)

9/25/23 @ 9:31 AM

We understand Ecology is planning an expansion of Type III designations. We ask that you stop this plan until a public evaluation of the costs and benefits of the expansion is done. Ecology should be transparent and public in its rule making.

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Comment From: Nathaniel Hayden

9/25/23 @ 8:56 AM

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Comment From: Wade Boyd

9/25/23 @ 8:54 AM

Unilateral government decrees such as the one you are proposing are gasoline on the fire which creates the frustration, anger and resentment of urban and rural communities empowering MAGA and efforts to overthrow our system of government.

Wake up ...↓

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Comment From: Cindy/WFPA Mitchell

9/25/23 @ 8:47 AM

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Comment From: wade boyd

9/25/23 @ 8:40 AM

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Comment From: Jerry Bonagofsky

9/25/23 @ 8:39 AM

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Comment From: wade boyd

9/25/23 @ 8:37 AM

Please postpone any destinations of Tier II waters until clear transparency has been met. Given that this is the first time ever that Ecology is designating these waters, a very high standard and clear and specific information should be available so ...↓

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Comment From: Ellen Anderson

9/25/23 @ 8:08 AM

I am in favor of protecting the Cascade River and support the designation of it as one of the four rivers listed as Outstanding Resource Waters.

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