Chapter 173-340 WAC, Model Toxics Control Act (MTCA) Cleanup Regulations - Proposed Rule Amendments

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Comment From: Carolyn Robinson

4/16/23 @ 11:52 PM
I am writing to you as a concerned member of the public. Like many of my fellow citizens, I care deeply about reducing toxic waste sites and their impacts on our communities. Please consider the below suggested changes to the documents now out for p...↓

We all deserve to live in a community where we can breathe clean air, drink clean water, and safely enjoy green spaces, rivers, and lakes. Tribes should be able to harvest healthy salmon, free from toxins, as they have since time immemorial.

As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

With your help, we can ensure that cleanups happen equitably. Communities deserve a strong cleanup rule that keeps them healthy and safe. There is no time to waste.
No attachments

Comment From: Landau Associates, Inc. (Piper Roelen)

4/16/23 @ 11:03 PM
Attachments:

Comment From: Geosyntec Consultants, Inc. (Ben Starr)

4/16/23 @ 9:27 PM
Attachments:

Comment From: Ben Starr

4/16/23 @ 9:21 PM
Attachments:

Comment From: Michelle Mood

4/16/23 @ 5:59 PM
I live near a Superfund site in South Tacoma, with commercial auto recycling businesses nearby, and very concerned about this clean up rule. My neighbors and I need the protection of law to be able to reduce our high environmental health inequities. ...↓

We all deserve to live in a community where we can breathe clean air, drink clean water, and safely enjoy green spaces, rivers, and lakes. Tribes should be able to harvest healthy salmon, free from toxins, as they have since time immemorial.

As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

With your help, we can ensure that cleanups happen equitably. Communities deserve a strong cleanup rule that keeps them healthy and safe. There is no time to waste.
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Comment From: Phil Harty

4/16/23 @ 4:43 PM
I am writing to you as a concerned member of the public. Like many of my fellow citizens, I care deeply about reducing toxic waste sites and their impacts on our communities. Please consider the below suggested changes to the documents now out for p...↓

We all deserve to live in a community where we can breathe clean air, drink clean water, and safely enjoy green spaces, rivers, and lakes. Tribes should be able to harvest healthy salmon, free from toxins, as they have since time immemorial.

As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

With your help, we can ensure that cleanups happen equitably. Communities deserve a strong cleanup rule that keeps them healthy and safe. There is no time to waste.
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Comment From: Olympic Environmental Coalitio... (Darlene Schanfald)

4/16/23 @ 3:00 PM
MTCA is a good and needed program, but it seems weaker than the original intent - comparable or stronger than the USEPA Superfund program. WA State cannot be "green" until these poisons can be gotten rid of.

Perhaps more staff is needed to work on th...↓
• cleanup schedules being met. Significant cleanups met in a timely manner.
• the PLPs should put significant funds up front to initiate and cover cleanup costs. MTCA can draw on these funds if the PLP is recalcitrant.
• more lawsuits against PLPs
• stop over representing cleanup costs. Rather, accurately reflect the costs to human health, wildlife and natural resources. There is no justification for leaving toxic and hazardous waste in communities. Polluters must remove these and MTCA should reflect this, as well as hardball positions it will take if PLPs don't advance cleanups.
• Determine and share with the public the cumulative impacts to human health, the wildlife and ecosystems.
• pay attention to cleanups in EJ and lower economic communities.
• include Equity in the SHARP tool
• always increase ways to reach and inform the public.
• give large weight to public comments. Don't just check a box that comments were asked for and received but that there is no regulation that says the public comments matter, which has been stated by Ecology staff. Don't waste the public's time and energy if their input is dismissed. Heavily weighe public input!

Thank you.
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Comment From: David Friscia

4/16/23 @ 12:42 PM
I am writing to you as a concerned member of the public. My day job is not to track these complicated processes, but I care deeply about reducing toxic waste sites and their impacts on communities. You can help by making the following changes to the ...↓

We all deserve to live in a community where we can breathe clean air, drink clean water, and safely enjoy greenspaces, rivers, and lakes. And Tribes must be able to harvest healthy salmon, free from toxics, as they have since time immemorial.

As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

● Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

● Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

● Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

With your help, we can ensure that cleanups happen equitably. Communities deserve a strong cleanup rule that keeps them healthy and safe. There is no time to waste.
No attachments

Comment From: DRCC, RE Sources, CHB, WCA, an... (Erin Dilworth)

4/16/23 @ 12:37 PM
Thank you again for providing the opportunity to comment on the proposed MTCA rule update. Duwamish River Community Coalition, RE Sources, Communities for a Healthy Bay, Washington Conservation Action, and Twin Harbors Waterkeeper offer the attached ...↓
Attachments:

Comment From: Stacy Oaks

4/16/23 @ 11:55 AM
My comment is attached
Attachments:

Comment From: K Anderson

4/16/23 @ 9:40 AM
As the Department of Ecology is updating the Cleanup Rule after nearly 30 years it's time to incorporate environmental justice and climate change considerations to reduce the burden on our most impacted communities. I am writing to you as a concerned...↓
We all deserve to live in a community where we can breathe clean air, drink clean water, and safely enjoy green spaces, rivers, and lakes. Tribes should be able to harvest healthy salmon, free from toxins, as they have since time immemorial.
As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.
The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.
These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:
Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.
Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.
Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.
No attachments

Comment From: kirk Kirkland

4/16/23 @ 9:29 AM
Please see letter from Tahoma Audubon Society attached.
No attachments

Comment From: Mark Galacgac

4/16/23 @ 9:02 AM
Attachments:

Comment From: Moriah Galacgac

4/16/23 @ 8:52 AM
Attachments:

Comment From: Meagan Galacgac

4/16/23 @ 8:47 AM
Attachments:

Comment From: Judith Kay

4/16/23 @ 7:56 AM
I write as a concerned resident of Tacoma. I care deeply about reducing toxic waste sites and their negative effects on my community. Please consider the following changes to the documents now out for public comment.

We all deserve to live in a commu...↓

As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxins, especially increased risks for cancer and neuro-developmental disorders in children. The environmental cleanup law doesn't currently factor this disparity when prioritizing sites for clean up. Toxic sites that affect our Tribes and people of color deserve be given priority.

I recommend these changes to the Model Toxics Control Act:

Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities,especially populated by people of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an over-representation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services, especially to public health.

Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

With your help, we can ensure that cleanups happen equitably. Communities deserve a strong cleanup rule that keeps them healthy and safe. There is no time to waste.
No attachments

Comment From: WSPA (Jim Verburg)

4/15/23 @ 10:28 PM
Attachments:

Comment From: Elly Claus-McGahan

4/15/23 @ 6:19 PM
I am a Tacoma resident, a retired teacher, and am very concerned about the need to preserve and remediate damage to our earth so that future generations can live and thrive. The rules need updating to increase public awareness and society's valuatio...↓

As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

By modifying the rules, we can ensure that cleanups happen equitably and with greater speed. Washington could lead in this area and it fits in well with Washington's current agenda to lead on climate response action. A healthy environment to live, grow, and play in for all promises a bright future for generations to come. Thank you
No attachments

Comment From: GHD Inc (Brian Peters)

4/15/23 @ 1:05 PM
Attachments:

Comment From: Felicity Janette

4/15/23 @ 12:46 PM
I am writing to you as a concerned member of the public. Like many of my fellow citizens, I care deeply about reducing toxic waste sites and their impacts on our communities. Please consider the below suggested changes to the documents now out for p...↓

We all deserve to live in a community where we can breathe clean air, drink clean water, and safely enjoy green spaces, rivers, and lakes. Tribes should be able to harvest healthy salmon, free from toxins, as they have since time immemorial.

As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

With your help, we can ensure that cleanups happen equitably. Communities deserve a strong cleanup rule that keeps them healthy and safe. There is no time to waste.
No attachments

Comment From: Carolyn Janette

4/15/23 @ 12:42 PM
I am writing to you as a concerned member of the public. Like many of my fellow citizens, I care deeply about reducing toxic waste sites and their impacts on our communities. Please consider the below suggested changes to the documents now out for p...↓

We all deserve to live in a community where we can breathe clean air, drink clean water, and safely enjoy green spaces, rivers, and lakes. Tribes should be able to harvest healthy salmon, free from toxins, as they have since time immemorial.

As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

** Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

** Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

** Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

With your help, we can ensure that cleanups happen equitably. Communities deserve a strong cleanup rule that keeps them healthy and safe. There is no time to waste.
No attachments

Comment From: Roberta Mantooth

4/15/23 @ 12:05 PM
Friends of Ennis Creek is finding MTCA inadequate for cleaning up toxic materials left in water and on land from Rayonier mill, which closed in 1997. Corporate stockholder profit seems to be prioritized over demand from individuals, governmental enti...↓
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Comment From: Janeen provazek

4/15/23 @ 11:39 AM
I am very concerned about the 14,000 plus toxic waste sites across Washington state that still need cleaning up. They exist in our neighborhoods, disproportionately affecting people of color and Tribes. Despite this, the state's environmental cleanup...↓
No attachments

Comment From: Kenneth Zirinsky

4/14/23 @ 11:21 PM
To the Washington State Dept. of Ecology,

I am writing to you as a concerned member of the public. My day job is not to track these complicated processes, but I care deeply about reducing toxic waste sites and their impacts on communities. You can hel...↓

We all deserve to live in a community where we can breathe clean air, drink clean water, and safely enjoy greenspaces, rivers, and lakes. And Tribes must be able to harvest healthy salmon, free from toxics, as they have since time immemorial.

As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

With your help, we can ensure that cleanups happen equitably. Communities deserve a strong cleanup rule that keeps them healthy and safe. There is no time to waste.

Thank you for reading this comment.
- Kenneth Zirinsky
No attachments

Comment From: Washington State Department of... (PATRICK SVOBODA)

4/14/23 @ 7:34 PM
The Washington State Department of Transportation (WSDOT) appreciates the opportunity to review and comment on the proposed changes to the Model Toxics Control Act (MTCA), Chapter 173-340 WAC. WSDOT will submit comments as directed by the Ecology li...↓

- Please include an abbreviation and acronym list.
- Please ensure definitions are consistent among the regulations Ecology has jurisdiction on. For example, a spill to the roadway that has been issued No Further Action (NFA) after the roadway cleanup is different if the spill has also migrated onto the adjacent soil that still requires cleanup. Using the same term NFA when applied is confusing to those wanting to ensure cleanup has been completed. Will both types of the NFA be included on Ecology's website?
- Clarify and or define "remediation", "mitigation", etc. Please include a definition of emerging contaminants and contaminants of emerging concerns.
- Please define, within this regulation, how dangerous waste and extremely hazardous waste apply in comparison to the Dangerous Waste Regulations. Chapter 173-303 WAC.
- Please add a reference to Chapter 173-303 WAC for the disposal of Investigative Derived Waste.
- WSDOT appreciates the proposal of "sites" as a replacement for "facilities". The term "site" can include linear projects and are more inclusive than the term facility.
- Please define indigenous/traditional knowledge.


- WSDOT does have an existing "inadvertent discovery plan" that it believes works with the language proposed in the rule.
- Please define a cleanup/remediation of a waste and further explain the steps for a cleanup alternative. WSDOT appreciates the flexibility being offered when considering human health impacts for cleanup.
- WSDOT is pleased that Ecology updated from the use of WARM with SHARP tool. Will there be additional workshops to further guide potential users of SHARP?
Is there a way to represent/identify homeless encampment issues? The ability to identify and categorize the associated issues will assist landowners that have potential liability.
- Please insert "environmental/social justice" as a consideration for cleanups. Please define or direct the reader where the associated details will be housed in this regulation, other regulations, or guidance documents.
- Adds "threatened" release with "discovery of release". Please clarify how threatened will be determined and if this with other such terms requires a process upfront or will be required for all areas.
- How will Ecology balance its relisting issue with NFA and other waste designations? What are the Cost and implications for third parties?
- WSDOT appreciates that Ecology proposes to extend the number of days, from 30 to 90, when there is a discovery of a release and the number of days for a report submittal.
- WSDOT seeks confirmation that cleanups under Independent remedial actions can be done prior to, during, or after the initial investigation. If there is a waiting period, please clarify those circumstances and situations.
- WSDOT seeks flexibility with notification/publication (i.e. site register) for cleanups, public comment periods, workplans, and cleanup plans addressing cleanups on events on WSDOT right of way.
- WSDOT seeks clarification if workplans, remedial investigation, and remedial actions can concurrently be submitted.
- Please clarify the need to monitor for groundwater contamination and the role institutional controls may have in that relationship.
- Please clarify monitoring requirements for surface water and groundwater contamination and where institutional controls can be used in lieu of them.
- Please clarify how homeless encampments do or do not apply within MTCA.
- WSDOT appreciates the definitions of a settlement, with an agreed order, and no settlement.
- In terms of Tribal engagement, how will Ecology work with other potentially impacted agencies when engaging the Tribes on applicable sites?
- If Ecology implements the green/resilient approach to clean up, will guidance including examples for specifics like monitoring, fuel usage, and terms like environmentally friendly lube oil be defined or examples of such products with this approach be available in an Ecology guidance?

Thank you again for this opportunity, please let me know if you have any questions.

Pat Svoboda
WSDOT ESO Hazardous Material and Solid Waste Program Manager
360-870-9491
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Comment From: Steven Storms

4/14/23 @ 6:27 PM
We, as a nation are killing ourselves. As Kurt Vonnequt said, "We'll go down in history as the first society that wouldn't save itself because it was not cost effective".

We produced toxic chemicals, but failed in cleaning them up. The toxic wastes ar...↓

We all deserve to live in a community where we can breathe clean air, drink clean water, and safely
enjoy greenspaces, rivers, and lakes. And Tribes must be able to harvest healthy salmon, free from
toxics, as they have since time immemorial. Despite this, the state's environmental cleanup law
doesn't prioritize cleanups in the places where we live.
The data is clear: People of color and low-income communities bear a disproportionate share of
health risks from exposure to toxics. This includes increased risk for cancer and
neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor
this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.
These changes must be incorporated into the Model Toxics Control Act through the current
rulemaking processes:
Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income
communities of color. In addition to the health impacts that stem from living close to these sites,
these communities also suffer from the consequences of living near other forms of pollution,
including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining
how they are cleaned, the cumulative impacts of living in areas where pollution is heavily
concentrated must be considered.
Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to
provide enough guidance to accurately represent the ecosystem services and public health benefits
of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option.
This leads to a consistent underestimation of the ecosystem and public health benefits and an
overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent
analysis that accurately represents the true benefits of ecosystem services and public health.
Public notice: All members of the public have a right to know about toxic waste sites and cleanups
happening in their communities. The current methods Ecology uses for public notification do not
make this information sufficiently accessible, especially for those without easy access to the
internet or technology. To ensure that the most effective communication strategies are being used,
Ecology must gather information about the affected communities to determine the best modes of
communication to reach them. In addition, Ecology must provide more effective outreach to the
general public about how to find information and receive notifications beyond the current obscure
website registry.
With your help, we can ensure that cleanups happen equitably. Communities deserve a strong
cleanup rule that keeps them healthy and safe. There is no time to waste
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Comment From: Barbara Church

4/14/23 @ 5:42 PM
I'm writing to you as a resident of Tacoma who lives within a 2 mile radius of the Port of Tacoma and near many toxic waste sites. A clean and livable environment where toxic waste sites are mediated or completely cleaned up is important to reducing ...↓


More than 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law needs to factor this into deciding when, and how, toxic waste sites are cleaned up.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

With your help, we can ensure that cleanups happen equitably. Communities deserve a strong cleanup rule that keeps them healthy and safe. There is no time to waste.
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Comment From: Christina M Jackson

4/14/23 @ 5:41 PM
I live right near the tacoma tide flats superfund site and live wit hthe pollution from this every day. I am very concerned on the impacts of this site on my community and this is a verty urban and dense area disproportionately housing BIPOC populat...↓

We all deserve to live in a community where we can breathe clean air, drink clean water, and safely enjoy greenspaces, rivers, and lakes. And Tribes must be able to harvest healthy salmon, free from toxics, as they have since time immemorial. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

With your help, we can ensure that cleanups happen equitably. Communities deserve a strong cleanup rule that keeps them healthy and safe. There is no time to waste.
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Comment From: Washington Conservation Action (Katie Byrnes)

4/14/23 @ 4:34 PM
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Comment From: Rachel Haxtema

4/14/23 @ 4:33 PM
I am writing to you as a concerned member of the public - an adjunct professor of Christian Ethics and community educator - and it is not my job to track these complicated processes, but I care deeply about reducing toxic waste sites and their impact...↓

We all deserve to live in a community where we can breathe clean air, drink clean water, and safely enjoy greenspaces, rivers, and lakes. And Tribes must be able to harvest healthy salmon, free from toxics, as they have since time immemorial.

As you know, most of the 14,000-plus toxic waste sites across Washington state still need to be cleaned up. Toxic waste sites exist in neighborhoods in our communities and disproportionately affect people of color and Tribes. Despite this, the state's environmental cleanup law doesn't prioritize cleanups in the places where we live.

The data is clear: People of color and low-income communities bear a disproportionate share of health risks from exposure to toxics. This includes increased risk for cancer and neurodevelopmental disorders in children. The environmental cleanup law doesn't currently factor this into deciding when, and how, toxic waste sites are cleaned up. This needs to change.

These changes must be incorporated into the Model Toxics Control Act through the current rulemaking processes:

Cumulative health impacts: Toxic waste sites in Washington are often clustered in low-income communities of color. In addition to the health impacts that stem from living close to these sites, these communities also suffer from the consequences of living near other forms of pollution, including airports, freeways, and Superfund sites. When prioritizing cleanup sites and determining how they are cleaned, the cumulative impacts of living in areas where pollution is heavily concentrated must be considered.

Disproportionate Cost Analysis: The Disproportionate Cost Analysis (DCA) currently fails to provide enough guidance to accurately represent the ecosystem services and public health benefits of a thorough, more protective cleanup when compared to the monetary cost of each cleanup option. This leads to a consistent underestimation of the ecosystem and public health benefits and an overrepresentation of the cleanup costs. Ecology must provide more guidance for consistent analysis that accurately represents the true benefits of ecosystem services and public health.

Public notice: All members of the public have a right to know about toxic waste sites and cleanups happening in their communities. The current methods Ecology uses for public notification do not make this information sufficiently accessible, especially for those without easy access to the internet or technology. To ensure that the most effective communication strategies are being used, Ecology must gather information about the affected communities to determine the best modes of communication to reach them. In addition, Ecology must provide more effective outreach to the general public about how to find information and receive notifications beyond the current obscure website registry.

PLEASE make these changes to ensure that cleanups happen equitably. All communities deserve a strong cleanup rule that keeps them healthy and safe. Your work to make this happen is crucial at this time and in this process.
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Comment From: Confederated Tribes and Bands ... (Laura Shira)

4/14/23 @ 1:31 PM
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Comment From: Port of Seattle (John Evered)

4/14/23 @ 12:02 PM
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Comment From: City of Tacoma (Merita Trohimovich)

4/14/23 @ 8:51 AM
Please see Tacoma's comments in the attached file.
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Comment From: Twin Harbors Waterkeeper (Lee First)

4/14/23 @ 5:33 AM
1. Outreach to communities that are closest to, and affected by contaminated sites should be increased. In my town of Aberdeen and Cosmopolis, cleanup actions should have articles in the local newspaper. Local community groups should be contacted ...↓
2. Cleanup actions in low income communities should be prioritized.
3. In my area of the Chehalis River Estuary, there are almost no cleanups occurring, yet there are over 161 contaminatedf sites. The Port of Grays Harbor appears to be an unwilling partner. Why? There are MANY MTCA sites on the Port's properties. Something needs to be done to begin cleanup on the Port's property.
4. Please increase the award of grant money to projects that incorporate environmental justice. Fund positions for language interpretation to increase language justice.
5. Cleanup of MTCA sites that are close to green spaces in low income communities should be prioritized.
6. Please add an equity element into the PPG application and PPG evaluation scoresheet.
7. Create an environmental justice board be created to ensure that environmental justice is adequately considered.
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Comment From: J.R. Simplot Company (Dedra Williams)

4/13/23 @ 11:00 AM
The attached comments are on behalf of the J.R. Simplot Company regarding Chapter 173-340 WAC, Model Toxics Control Act (MTCA) Cleanup Regulations - Proposed Rule Amendments.
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Comment From: Lauren Carroll

4/04/23 @ 5:56 PM
Ecology needs to put science first in its decision-making process, and prioritize true risk from there.. From my review of state-wide projects, municipalities and ports receive millions of dollars in tax payer funded MTCA Remedial Action Grants based...↓

Much of the administrative language in the new rule seems to be policy written to make the RAG funding even easier for ports and municipalities to get there hands on.

On the flip side, the lack of thorough scientific oversight at these sites is frightening with regard to what is pushed beneath the radar. Example:

Ecology and Environment conducted a Targeted Brownfield Assessment (TBA)at the Seaport Landing Site in Aberdeen. This site was a former mill donated by Weyerhaeuser for redevelopment as a park. The TBA states that concentrations of thallium in soil samples were "in line with naturally occurring background concentrations". Ecology (WAC 173-340-709) provides detailed procedures for calculating site-specific natural background concentrations. These procedures were not followed; the thallium concentrations are not background. Thallium is known as "the poisoner's poison".

The concentrations of thallium in soil samples collected at the site by E&E ranged from 1.8 milligrams per kilogram (mg/kg) to 6.2 mg/kg, which exceed MTCA's direct contact cleanup level of 0.8 mg/kg. Lethal doses of thallium in humans are within this range.

Thallium was used at a rodenticide and insecticide until it was banned in 1972. It is easily taken up and concentrated in plant tissues. In 1954, Weyerhaeuser participated in a study in which pine forests were treated with thallium sulfate as a rodenticide. It is postulated that thallium in the surface soils is related to the metal being concentrated in wood ash from refuse burners that were spread out on the property.

Seaport Landing is being redeveloped as a park and recreational area with grass and open areas.
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Comment From: Lauren Carroll

4/04/23 @ 4:55 PM
One of the stated purposes of the proposed rule change (page 2) is, "...maintain federal approval of the state's UST program, as required by Chapter 70A.355 RCW. I do not think that Washington is worthy of maintaining federal approval of the state's ...↓

An example follows:

In 2017, Pacific Crest Environmental provided documentation to Ecology regarding the discovery of an orphan UST on a neighboring property we were investigating, but which did not belong to our client. On February 17, 2017, a report was filed with Ecology that included photos, description and location of the UST, and referenced the owner's removal obligations in accordance with WAC 173-160. In a response letter received from Ecology, receive fourteen months later, on April 30, 2018, Ecology stated: "Ecology agrees that the orphan UST, if present, should be properly decommissioned...However, photographs provided in the report do not clearly show the presence of a UST" (Report attached).

There were indeed two USTs on this property, which were removed in 2020 under the direction of UST Certified Site Assessor Brandon Miller of CDM. However, CDM's UST site assessment checklist was not prepared by Brandon Miller, and the person that prepared the checklist was not on-site any time during the removal activities. Ecology has been made aware of this situation, but does not appear to concern itself with such mundane matters as UST regulations.

Ecology's UST program is to be at least as stringent at those promulgated under 40 CFR 281 to maintain state program approval. I don't think we're there.
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Comment From: Lauren Carroll

4/04/23 @ 4:02 PM
A meaningful appeals process must be established in the MTCA Cleanup Regulation as a check on Ecology's integrity in its decision-making process. It is my hope that this would be overseen by the state legislature, as they are at least accountable to ...↓

Under the existing structure, Ecology personnel may act in bad faith without consequence, and are at risk of becoming motivated by corrupt purposes. Opinion letters issued by Ecology carry the following disclaimer: "The state, Ecology, and its officers and employees make no guarantees or assurances by providing this opinion, and no cause of action against the state, Ecology, its officers or employees may arise from any act or omission in providing this opinion."

I provide the following information by way of example:

In June 2014, Nnamdi Madakor, the former technical manager of the Voluntary Cleanup Program (VCP) sent out an email to his team requesting examples of sites at which a consultant was attempting to establish a non-potability determination. Ms. Heather Vick responded by providing the Aoki Site as an example, and provided a false and defamatory statement behind the technical reason we were seeking this determination: "The case with Aoki is that the consultants were attempting to show that there is non-potable ground water on the Site...in order to preclude cleanup."

Mr. Madakor took Ms. Vick at her word and utilized my firm's work as an example in a VCP-wide Steering Committee meeting held on June 11, 2014. Unfortunately, my firm's reputation was diminished by this act. We were provided no means to which to reply or clarify this wrong-doing, and instead only learned of it incidentally through a public records request.

The effort to obtain the non-potability determination for the Aoki Site was to establish a groundwater cleanup level based on vapor migration to indoor air, the only viable pathway for receptors to groundwater contamination during the cleanup process. Further, Miss Vick provided a false and misleading statement to Mr. Madakor. Groundwater cleanup has been on-going at the Aoki Site since 2006. A fact that Miss Vick was surely aware of: as project manager she testified in King County Superior Court on behalf of the plaintiff, Madrona Real Estate Investors (Madrona)in 2013.

The outcome of the trial found that Madrona had a 15% liability for cleanup due to contribution of tetrachloroethene (PCE) contamination source on an adajcent property. Accordingly, the judge named the property the "Aoki/Madrona Site". However, Ecology refused to accept the courts findings. Ecology's Attorney General responded to my inquiry as to how to administer the project going forward with the following response forwarded by Vick dated August 16, 2016: "As promised, I spoke with VCP Unit Supervisor Louise Bardy and Ecology's Assistant Attorney General, Allyson Bazan, today about the legal document you provided. Both stated that the order contained in the document is not applicable to Ecology's determination."

Ecology has apparently determined that it is not accountable to court rulings, and insisted that the site name remain the "Aoki Site".

This situation is unjust and untenable.
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Comment From: Lauren Carroll

3/30/23 @ 12:15 PM
Comment 1: The Proposed Rule must include a section on Ecology's commitment to transparency, fair and equal treatment to all parties, ethical character, and adherence to the rule of law in all of its interactions. The Washington State Legislature sho...↓

On August 19, 2020, I received documents in response to a public records request (PRR) for a cleanup site known as the "Uptown Bakery Site". Ecology's project manager at that time was Heather Vick, her supervisor, Louise Bardy. Emails in that file disclosed that my firm, my name and work product had been used as an example of unscrupulous consulting practices at an Ecology meeting in 2016. This meeting included the entire Voluntary Cleanup Program (VCP)team and members of the attorney general's office. This "example" was based on a request for No Further Action (NFA) determination following a year of clean groundwater sampling. The condition of NFA had been discussed and agreed upon in a meeting with Ms. Vick in 2014. In the 2014 meeting, and as presented in a Remedial Investigation Report in Ecology's files, it was discussed that there was a small area of soil contamination present, but which was not impacting groundwater, so there was no risk to human health or the environment.

On August 19, 2020, following review of this malicious slander, I sent an email to Ms. Vick, Ms. Bardy, and other persons at Ecology stating that I was the victim of Defamation of Character by the department.

In early 2021, I received additional public records showing that on August 19, 2020, twenty minutes after I sent the Defamation of Character email to Ms. Vick, she sent a "High Importance" message to Public Records Officer Michael Hart, stating, "I thought I was going to get to review the list of emails to be sent prior to them being sent....What happened?"

In early 2021, I submitted a PRR to Ecology for the Aoki Site, for which Ms. Vick and Ms. Bardy were installed in similar capacity as the Uptown Bakery Site.

In an email from Ms. Vick to Ms. Bardy dated January 19, 2021, Ms. Vick stated that she "removed the Site name from the forwarded email", instead referring to it as the "A" Site, and stating that "I plan to delete this email to you after sending it." An additional email string between Ms. Vick and Mr. Brad Augustine (a real estate developer and owner of adjacent parcels)also refer to the site as the "A Site". It is only because Ms. Bardy did not delete her email, and later included in a string that included the work "Aoki", that I received this information.

Conclusion: Instead of making an effort to revise its ethics following my Defamation of Character email in August 2020, Ecology chose to adopt even more unscrupulous practices to avoid public disclosure, including coaching select outside parties on its methods. These activities constitute injury to public record, which is a crime under RCW 40.16.010 - Injury to public record. As stated, "Every person who shall willfully and unlawfully remove, alter, mutilate, destroy, conceal, or obliterate a record, map, book, paper, document, or other thing filed or deposited in a public office, or with any public officer, by authority of law, is guilty of a class C felony and shall be punished by imprisonment in a state correctional facility for not more than five years, or by a fine of not more than one thousand dollars, or by both.[ 2003 c 53 § 214; 1992 c 7 § 34; 1909 c 249 § 95; RRS § 2347.]"
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Comment From: Oulwa Research Studio (Octavia Parker)

3/22/23 @ 8:25 AM
Acknowledgments. As international civil servants, we must avoid situations and activities that may reflect adversely on the Organisation or compromise operations. I would like to express my gratitude to the Washington State Department of Ecology and ...↓

Signed,

Year: March 21, 2023 1:00 P.M. EST

Octavia Parker,

Octavia@oulwa.xyz
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Comment From: Judith Taylor

2/21/23 @ 6:34 PM
All the state Ecology Dept ever seems to do is TALK about planning and how they need more time to do develop a plan -- at least that's their history since Rayonier left waterfront property a toxic waste zone, from soil to sediment, 26 years ago. We n...↓
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Comment From: Andrea Moore

2/21/23 @ 5:50 PM
I live near a toxic site owned by Rayoneir Forest Products. This site is reviewed every two years and yet nothing has been done. It's a waterfront property in my town, which is a small town that relies on tourism income and an adjacent trail to the s...↓

The town is living in the shadow of an era where the forest industry once created livelihoods but now has left behind toxic oceanfront property and lost livelihoods. Port Angeles is in need and many of its residents have not recovered from the loss of industries which rely on natural resources. First Nations tribes in the area of restored a damned river ecology and made an incredible example of what can be done to reverse damage done from previous times.

The Rayonier site presents a similar opportunity and would benefit from the proposed rule amendments. I am in favor of the rule amendments because the state of Washington will benefit from cleaning up toxic sites, supporting the areas and people and the tourist economy and relations between First Nations people, the lands we have left to restore and our reputation as an "Evergreen" state.
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Comment From: Elaine Bailey

2/21/23 @ 11:19 AM
the proposed updates to Toxic Cleanups is an excellent addition. The unfortunate side of this is will it take even more time for actual cleanup to begin on the Port Angeles site? It is long overdue!
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