Our Sound, Our Salmon Comments on Draft Cooke Aquaculture National Pollutant Discharge Elimination System (NPDES) water quality permit modifications to raise steelhead

Comments developed by Wild Fish Conservancy and supported by a coalition of ten organizations addressing proposed modifications to Cooke Aquaculture’s existing water quality permits through the Department of Ecology as a result of the company’s application to transition their Puget Sound net pens to rear steelhead/rainbow trout.

These comments conclude:

“It is obvious that the current NPES permit process must be delayed until the Court issues a ruling in the lawsuit challenging the underlying SEPA review as an EIS may be required and would need to be considered in order to comply with SEPA. Similarly, Ecology should delay the permitting process until federal ESA consultation of the impacts Puget Sound net pens pose to ESA-listed species is complete and Ecology can incorporate any reasonable and prudent alternative measures that result from the consultation.

The modified permits fail to account for changes in risk assessment imposed by HB2957 and to “eliminate commercial marine net pen escapement” and “eliminate negative impacts to water quality and native fish, shellfish, and wildlife” as intended by the Washington legislature in passing this law. In adhering to this standard, we continue to encourage Ecology to treat Cooke’s applications as a new project, not an extension of an existing practice.

Lastly, the faith-based and retroactive regulatory framework currently used to enforce the NPDES permits cannot be effectively enforced to prevent catastrophic events before they occur and must be addressed before the permits are granted. Ecology must have the authority and
capacity to conduct regular and unannounced site visits and to conduct any biological sampling and testing deemed advisable to assure the public that no adverse impacts are occurring.”

Click download below to review the full comments.