03-30-2021, Comments Provided on Marine Net Pen Facilities in Puget Sound, Proposed NPDES General Permit (for Tribal Enhancement and Federal Research), Washington; USEPA

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 Net Pens holding Salmon in the Faroe Islands (in the north Atlantic Ocean, halfway between Iceland and Norway)

Photograph Attribution: By Erik Christensen - Own work, CC BY-SA 3.0, https://commons.wikimedia.org/w/index.php?curid=38663773

 

 

Introduction

 

The EPA is proposing a new National Pollution Discharge Elimination System (NPDES) General Permit for Net Pens operating in Puget Sound, Washington State. This new permit will apply only to net pens operating in the Puget Sound as opposed to the entire state of Washington. The General Permit will provide coverage for both tribal enhancement of marine net pen facilities as well as federal research for net pen facilities. This permit will address regulatory requirements and discharge limits.

 

 

Comments

 

 

 

March 25, 2021

 

 

Martin Merz– Regional Contact

US Environmental Protection Agency Region 10

Park Place Building

1200 Sixth Avenue

Seattle, WA 98101

 

 

Re: Proposed NPDES General Permit for Tribal Enhancement and Federal Research Marine Net Pen Facilities within Puget Sound

 

 

Dear Mr. Merz:

 

 

Environmental Review Inc. has reviewed the Proposed NPDES General Permit for Tribal Enhancement and Federal Research Marine Net Pen Facilities within Puget Sound, and has the following comments:

 

 

1)    Under Section III, Fish Feed (C) states that “Other monitoring practices that ensure feeding rates are appropriate” will be utilized. These other monitoring practices should be further explained for clarity. 

 

 

2)    According to the Fact sheet under section VI. Monitoring Requirements, subsection A. Sediment Characterization, it is stated that if fish are released early during the second year of the permit term, at a facility that operates for less than 6 months a year, the sediment characterization test may be postponed until the next year. This was not explained in the permit draft.

 

 

Sincerely,   

                

Anna Pigott                                   

Reviewer (Associate in Hawaii)     

        

 

Dwight Snow P.E. 

Sr. Reviewer (Associate in New Hampshire)

 

 

Environmental Review Workshop

(Environmental Review Inc., a 501(c)(3) nonprofit public benefit organization)

1792 Rogers Avenue

San Jose, CA 95112