TM Gandhi - Article: Comments in Puget Sound

THERESA MARIE GANDHI

Supporting Sustainable Life

October 26, 2006

Comments to:
Restoring Puget Sound Ecosystem Health for Future Generations:
Draft Recommendations of the Puget Sound Partnership
Preliminary Draft for Public Review October 13, 2006
From: Theresa Marie K. Gandhi, Washington State native for 60 years

I am qualified to submit comments because of my experience of working for a Healthy Puget Sound since 1980;

To stop the Northern Tier Underwater oil pipeline by preparing a bibliography of the Economic Viability of the Marine Resources of Puget Sound that would be at risk;

March 26, 2001 started organizing Island County Citizens by explaining the peer review scientific studies on the harmful effects of herbicides used to control roadside vegetation resulting in No Spray approved by County Commissioners April 1, 2002;

I with other representatives of Island County organizations we challenged WSDOT starting March 2002 to stop herbicide use for roadside vegetation control on State Routes in Island County resulting in 40% reduction from 2003 – 2005 and RoundUp® use at pavement edge stopped on other State Routes.

Submitted comments to BLM’s plan to spray herbicides on one million acres in twelve western states for fire suppression control, 2006;

Submitted comments on WIRA 6’s Puget Sound Salmon Plan March 2006. I made recommendations for involving landowners in their unfunded and unknown mandate to save the salmon and their habitat on near shores, wetlands and streams of Island County.

The draft of Restoring Puget Sound Ecosystem Health for Future Generations and Governor Gregoire’s call to create a Puget Sound Partnership to make this happen by 2020 is a wonderful vision, a brush stroke of the issues needing to be addressed, possible realities and processes to realize the vision, are actions whose time has come. I hope it is not too late or falls short because of scientific studies being ignored. I was greatly inspired reading the draft and hope that my comments and recommendations contribute in a positive way to the success of the vision and process. I only wish I had more time to devote to this as I only came to know about the comment period six days ago. I would hope that I will be allowed to submit later the data I have coming from WSDOT requested of Ray Willard. And also data to be gathered by submitting a PDA request for documentation of what I report here from Department of Agriculture and Department of Ecology.

What follows are documents that I am submitting as part of my comments. The first set focus on one of Puget Sound’s biggest threat: Toxic storm water run off and Washington State Department of Transportation – WSDOT’s contribution to this problem. It seems totally illogical to me to enlist the public and business to save Puget Sound while the agencies of Washington State spend hundreds of thousands of dollars, maybe more, to put toxic chemicals into the wetlands, streams, near shore and Puget Sound. No one has taken an inventory of the volume of these toxic chemicals used by the public, PSE, Golf Courses, schools, parks, noxious weed boards, and County Public Works road side herbicide vegetation control, Washington State Departments of Agriculture, Department of Ecology (the permitting czar) and WSDOT. No testing has been done on ground water, wells, the majority of streams, rivers, near shore and Puget Sound that I am aware of on the active ingredients of herbicides, pesticides, fungicides, etc. and the “Trade Secret” ingredients that can make up to 97% of the formulation in the form of (so called) inerts, surfactants, adjuvants and dyes. No testing has been done by the EPA on the synergistic effects of multiple toxic chemicals mixed by application and storm water run off. Normally I would put the list of documents submitted at the end of the body of comments. As this Plan is so complex I will follow a different format and address topics as a whole and move on to the next topic. The following are a mix of press reports, my letters to the Governor on the topic and comments submitted to WSDOT that were ignored.

Documents submitted with my comments:

“Toxic Stormwater is one of the Sound’s biggest threats” Seattle P-I as part of a series by Robert McClure and Lisa Stiffler on Broken Promises the Sound in Crisis October 11, 2006.

WSDOT Secretary Doug McDonald’s letter to the editor Seattle P-I October 14, 2006 in reaction to above article in “WSDOT takes seriously its commitment to Sound”.
October 24, 2006 letter to WSDOT’s Ray Willard requesting amounts and cost of herbicides used in all Puget Sound Counties on State Routes and Highways 1999 – 2006. He has agreed to respond with data on 2003 – 2005 use by next week. The remainder of my request will need to be submitted as a PDA request that can take up to six weeks for a response. I request that I be allowed to submit this data as I receive it.

A brief history of work to get WSDOT to change its ways will explain why an EIS Risk Assessment does not represent the truth about the risk of herbicides being used. March 26, 2002 met with WSDOT Secretary Doug McDonald and then submitted 175 pages of peer reviewed scientific studies documenting the “Gender Bender” aspects of herbicides applied to all State Highways and Routes along with 2,000+ petition signatures to Stop Spraying in Island County. (These documents are available upon request) Secretary McDonald called for an EIS Risk Assessment but Ray Willard ignored the “Gender Bender” Science by blocking out any input of the design of the study and constructed a Risk Assessment made up only of Chemical Corporations’ self serving studies. Washington Toxics Coalition and the N.W. Coalition for Alternatives to Pesticides submitted comments. These comments were declared: “Too complete and comprehensive” to be included in the Risk Assessment. Ray Willard declared that only two or three issues could be addressed in the hundreds of pages of the Risk Assessment. The Comments were not included in the Risk Assessment nor were they ever addressed by WSDOT just like the initial peer reviewed scientific studies that I and WEAN had submitted to Secretary McDonald that started the whole process. WSDOT then put the Risk Assessment on its web page as an example of how it was acting for the common good. Far from it as the following documents show. Secretary McDonald may not know of the extent of this fraud.

Seventeen page comments submitted to the WSDOT EIS Risk Assessment by Washington Toxics Coalition and N.W. Coalition for Alternatives to Pesticides that was illegally rejected, not dealt with and not included in the Risk Assessment. The risks are much greater than State agencies will admit by refusing to deal with the issues raised by the peer reviewed scientific studies. This is unconscionable hubris and the reason Secretary Doug McDonald thinks that WSDOT has a commitment to Puget Sound when the actions of his employees block the true implications of the risks.

March 30, 2005 letter to Governor Gregoire regarding WSDOT being in violation of WAC 173-270-040 passed in 1991. Rather than reducing herbicide use WSDOT doubled its use in the eleven years following. Not until Whidbey/Camano Island No Spray Coalition; Whidbey Environmental Action Network, Whidbey Island Chemically Injured Network, Washington Toxics Coalition and N.W. Coalition for Alternatives to Pesticides challenged WSDOT’s use of toxic chemicals for roadside vegetation control did changes begin to take place. No response from the Governor.

January 17, 2006 I wrote Governor Gregoire that the Puget Sound Partnership Goals were unattainable because Washington State agencies: WSDOT, WSDOA and WSDOE (transportation, agriculture and ecology) were spending hundreds of thousands of dollars (possibly more) to put toxic chemicals into Puget Sound via Storm Water run off. No response from the Governor.

April 2006 Town Hall Meeting I spoke to this issue at the microphone and handed Jay Manning, Department of Ecology a copy of the letter to the Governor and the supporting documentation. No response from Jay Manning.

Demark Bans RoundUp® from their Country because it migrated to drinking water five times faster than allowed.

Air quality and low oxygen levels linked:

Comments:

Currently satellite images of Puget Sound show a black cloud above the Strait and Puget Sound shipping lanes from the burning of cheap bunker oil. Every seven minutes or less 24/7 a ship passes by Whidbey Island into ports from Vancouver, BC to Tacoma leaving this smog trail. Washington State Ferries also contribute to this black cloud above the Straits and Puget Sound. The particulate matter from this and carbon monoxide from trucks, autos and industry are carried by rain into Puget Sound Waters and tie up oxygen needed for life under water.

The Dead Zone in Hood Canal is also being contributed to by the use of phosphate based detergents, toxic chemical yard care products as storm water run off containing herbicides used by Counties and WSDOT for roadside vegetation control. If perk tests were done during the winter rains on old septic systems it would probably be found that they no longer pass the perk test.

The Chesapeake Bay had a fish die off of 14 million fish when the “cell from hell” that was both vegetable and animal and as a dinoflagellate secreted a neurotoxin into the fish and then ate the back half off the fish. It caused neurotoxic effects in humans that it attacked. It emerged when an ancient phosphate mine’s tailings washed into the Bay along with raw hog waste equal to the human waste of 15 million people. The containment lake broke and a wall of waste six feet high rushed down the Neuse River and into the Bay combining with the phosphate making an ideal breeding ground for this ancient shape shifting toxic worm. This was documented in a book called: “And the Waters Turned to Blood” by Rodney Barker.

A recovery plan called Chesapeake 2000 called for two decades ago is similar to the vision of Puget Sound Partnership but it has failed and the Bay’s health declined as reported in: “Puget Sound is in trouble, but many still don’t get it”, October 14, 2006 by Lisa Stiffler and Robert McClure P-I reporters. Article included as supporting document.

Comment: If restoration is to work on Hood Canal’s Dead Zone:

Phosphates based detergents often used as a surfactant in herbicide formulations and in clothes washing products, are very toxic to marine life and often are not tested for their presence. Any hope of cleaning up and reviving Hood Canal’s Dead Zone will require a majority of residents to change their buying habits and realize what goes on the lawn, roadside and down the drain ends up in Hood Canal. In the 1960’s fishing in the lakes above the canal with only a few summer cottages you could see clear to the bottom of the lake. Now the lakes are cloudy, the frogs dead or deformed and the fish only there when stocked by Fish and Game.

“Marine life is disappearing from Puget Sound, and fast” October 9, 2006 by Robert McClure and Lisa Stiffler P-I Reporters. Off of Blake Island State Park lush meadows of eelgrass where crab live were nearly gone, only one sick crab was found. Similar reports have been received by divers off of Whidbey Island. Article included.

Comment: How toxic chemicals migrate through fauna and into Puget Sound Water Systems:

A book that we can learn from in this regard is “Wormwood Forest: a Natural History of Chernobyl” by Mary Mycio reporting on how Cesium-137 and Strontium-90 have migrated through its human, faunal and floral inhabitants and through the rock strata of a huge estuary, wetlands, river system and thus into the drinking water. It is as if a diagnostic nuclear medicine scan has been preformed showing how toxic substances migrate through plants, land, rock strata and into the water systems that feed a body of water like Hood Canal.

A book that should be required reading for all who participate in the Puget Sound Partnership is “The 100 Year Lie” by Randall Fitzgerald. His research documents the history of the development of synthetic chemicals since 1906 and the history of diseases that grew as more and more toxic chemicals entered out lives. Chemical Corporations now produce six cups of pesticides for every man, woman and child in the United States. Not dealing with the total threat from the ubiquitous presence of these chemicals with changes in laws, enforcement and even banning from the state will doom the vision and plan of a clean Puget Sound from achieving its goals. We could start by banning the advertising of products like RoundUp® as New York has done. And like Demark ban RoundUp® from being sold in the State. At the least require a “This product kills salmon and feminizes males of all species in the environment” warning label.

Comment: Suggestions to eliminate toxic chemicals in our environment, bodies and waters:

At the very least anyone who purchases a product designed to kill should be required to get a Cide License after becoming educated in the risks of using toxic chemicals including the Chemical Corporations very small print on their products saying that the buyer is libel. PestiCide means to kill pests. These toxic chemicals have been proven to be causal in a number of diseases that cost huge amounts of money for the State to treat and risk the elimination of multiple species in our environment.

National Marine Fisheries Service, Salmon Recovery Division recently created a Puget Sound Salmon Plan. I submitted comments and recommendations March 16, 2006 on the WIRA-6 portion. This plan puts the major responsibility of saving salmon on property owners but has no process or plan to educate the public of its responsibility and unfunded mandate.

Comment: A Possible Educational Process to save Puget Sound:

Recommendations that I made as part of my comments on WIRA 6’s Salmon Plan are included as part of my comments submitted today. Additionally in speaking with Island County Salmon Plan staff recently I suggested a process to educate the public and get them involved in solving the problems relating to the issue at hand, saving salmon. I suggested an adaptation of the ‘Great Decisions” Study Group process created by (as I recall) the University of Chicago. They worked from a newsprint magazine format that outlined twelve different topics describing the challenge for discussion with a list of questions to discuss. Local groups would meet monthly and discuss through the year twelve different issues and submit their consensus report to be assembled and reported to all the groups that participated as a report for the beginning of the next year’s cycle. The topics discussed in this 1979 model related to foreign policy but it could be created as a way to educate and involve community groups throughout Puget Sound to have an investment in seeing the changes happen.

3.3 Recommended Essential Priorities of a Healthy Puget Sound by 2020

Comments: Paragraph four - …As with the other recommendation in this draft report, these initial priorities are a work in progress……Under a small list of top actions I would like to suggest that removal of creosote soaked pilings proceed as fast as possible. Tony Frantz has been working with government agencies to do removal without releasing the creosote into the water ways in the process. He has invented a unique system of slipping an enclosure around the piling and then lifting it out. He can better document, and explain the process. He can be reached here on Whidbey Island via fishfriends@hotmail.com 360-331-1606. He has participated in removing hundreds of creosote logs from the beaches of Whidbey Island and Puget Sound and came to do this after developing a chemical sensitivity to the creosote from years of working around the chemical.

A. Protect Existing Habitat ……. Key Immediate Priority Actions:

Comment:

1. With out enforcement of Critical Areas Ordinances and Shoreline Master Program rules this will not succeed. A pro I-933 person is building a home with the foundation on the shoreline without the proper permits and in violation of rules without enforcement from Island County. Often permits are issued after violations have occurred with a wink and nod and a please don’t do this again, but they do as it was so easy in the first place. A landowner on Camano Island is illegally bulldozing a stream to make himself a lake and nothing is done.

3. A rescue tug at Neah Bay was needed years ago and this can not wait as it is a key recommendation of the Oil Spill Task Force. Additionally since oil companies have spilled vast amounts off of Edmonds that polluted shell fish across the bay in Kitsap County a better monitoring system and enforcement needs to be in place everywhere that oil is off loaded within all the waters of Puget Sound including the Strait of Juan de Fuca and Vancouver, BC.

A system with enforcement abilities needs to be in place to ensure that bilges and waste systems are not dumped within three miles or more of entering the Straits by the cruise ships and vast number of cargo ships. Honor Shipping Companies that are good stewards and expose those that are not and let it be known whose goods they carry of the bad ones, like Wal-Marts’ Chinese ships.

C. Significantly Reduce Toxics Entering PS …….

Key Immediate Priority Actions:

2. Conduct a toxic source characterization of sources……

Comment: Data collected from WSDOT’s Risk Assessment of Herbicides in the Environment can not be trusted for it accuracy as documented by supporting data submitted by this author. The Gender Bender aspects of the herbicides and the implications for multiple species extinction are much greater than the Chemical Corporations’ studies used to document WSDOT’s safety record in their Risk Assessment. Reference comments submitted to WSDOT but not included by WA Toxics and NCAP included by this author as supporting documentation.

F. Provide Water for People, Fish………

Comment on identifying water needs: County inventories and mapping for growth and limit of industry in Puget Sound areas are not adequate. In Island County with no rivers, aquifer recharge rates depend upon rain fall and withdrawal rates. These have not been mapped taking in the factors of growth and global warming that could result in years of little or no rain like this years 105 days of no rain. Wells are already drying up and or having to be drilled deeper. Salt intrusion has occurred in past years.

H. Build and Sustain our Capacity for Action

Comments:

Suggestions of possible solutions from this author:

Create an awards and acknowledgement system to support a culture of stewardship among all residents.

Make a salmon friendly lawn a status symbol of good stewardship.

Use the “Great Decision” Study Group process as explained previously in this document to create a sense of ownership in communities saving Puget Sound.

Encourage groups in place like Beach Watchers, Orca Network, etc.

Have business adopt an intern in college programs that focus on preparing students to work in environmental programs that contribute to

Saving Puget Sound.

Support the building industry switching to green friendly building practices and designing green buffers for storm water run off in developments.

5.5.4 Executive Director and Staff

c) …….establish Sound wide data monitoring system……collection and evaluation of data.

Comment: Test for the presence of the “Trade Secret” ingredients in the formulations of herbicides not just the “active ingredient” which is often only 3% of the total formulation. Especially look for the presence of known “Gender Bender” chemicals used in these formulations. Ingredients like POEA – polyeth-oxylal-edtallow-amine are longer lasting and much more damaging than the “active ingredient” in RoundUp®.

6.4.1 Estimating Resource Needs for Key Puget Sound Priorities

c) Managing the Impacts of Stormwater

Stormwater is the most ubiquitous of environmental challenges……..

Comment:

Support all Puget Sound County Public Works to shift to No Spray of herbicides for roadside vegetation control. Currently six Counties are No Spray: Island, Jefferson (25+ years), etc.

Fourth paragraph: WSDOT working to construct stormwater runoff treatment and flow control……….

Comment:

WSDOT is a major contributor to toxic chemicals in stormwater by continuing to use herbicides for roadside vegetation control. Road side construction design needs to change, native plants restored to roadsides rather than cheap foreign seed mix 47 that opens the roadsides for invasive noxious weeds and creates the need for herbicide application where if the road construction design from the beginning supported mowing and native plants this problem would not exist. It is not too late to start and WSDOT has made strides especially in Island County where the community demanded it but they have not eliminated the use of toxic chemicals. This needs to happen.

d) Improving Wastewater Treatment

Comment:

Canadians need to be involved in this process:

The draft plan in section 6.4.1 d) mentions that one half million gallons of nutrient waste enters Puget Sound daily. This is a gross understatement as Victoria, BC discharges 34 million gallons of untreated raw human waste daily into the Strait of Juan de Fuca and thus Puget Sound. “Victoria revisits issue of treating its sewage” by Jonathan Martin Seattle Times staff reporter July 2006. And in the Seattle P-I July 14, 2006 by Associated Press on a report by Dr. Bill Stubblefield, chairman of the Society of Environmental Toxicology and Chemistry North America. Brown clumps of this human waste wash up on San Juan Islands. Water samples found fecal coliform bacteria at 1,400 times the Canadian national standard just above the discharge pipes. This will require diplomacy and maybe even boycotts of Canadian goods to pressure Victoria, BC to be a good neighbor.

Additionally there needs to be greater enforcement of rules to stop ships from discharging bilges and human waste close enough to the entrance to the Strait of Juan de Fuca that it comes in with the tide.

Appendix A. Ecosystem Goals, Outcomes, and Potential Benchmarks

A.2.1 Goal: Puget Sound species and the web of life thrive.

Reasons for species decline are complex and can become self-reinforcing.

Comment: As explained to me by Chad Phillips Washington Department of Agriculture’s Spartina Program Director in his fourth hour on his new job, the department is phasing out its use of Rodeo® for control of Spartina and has switched to Imazapyr®. Rodeo® is RoundUp® wet for aquatic uses and is a “Gender Bender” toxin. Chad told me October 23, 2006 that as the vast meadows of Spartina are brought under control, hand pulling during summer minus tides is then done. This is good news. I have not yet had time to track down toxicity studies on the formulation of Imazapyr® produced by United AG. The history, goals and Spartina Management Plans for past and present years can be found on their web page: www.agr.wa.gov.

The Department’s use of Rodeo all these years could be a major contributor to the death and deformities found in crab populations, the decrease in herring and feed fish for salmon and other large fish as toxins bio-accumulate up the food chain with the whales and humans receiving the most. But along the way all species are experiencing the feminization of the males with eggs found in male salmon and diminished reproductive organs throughout multiple species of marine life and those who eat it.

A.2. Ecosystem goals and outcomes

A.2.1. Goal: Puget Sound species and the web of life thrive.

Potential benchmarks for Species/Food Web Outcome 1

Comment: What is not mentioned as a benchmark is the health of frogs in wetlands and streams. World-wide frogs are disappearing, have five legs, two heads and mixed genital. What was found in Chernobyl was that life continued and massive die offs did not occur. In fact many species that had not lived in the area when it was populated and the nuclear plant was running have returned and species not seen in decades have returned. There were less die-offs of multiple species from the radiation compared to the United States where huge die offs have occurred where toxic chemicals have been used. What happens in upland streams and wetlands migrates to near shore and into Puget Sound.

That DNR just recently accepted the concept that logging steep slopes degrades salmon breeding areas in streams needs to be turned around. The Forest Service (i.e. Tree Farm Agency) that subsidized logging companies by building roads that degraded streams needs to go back and rectify all past actions that taxpayers paid for by retroactively billing the logging companies for the actual cost of their logging all of these past decades. Failure to participate in this process should result in a ban of that logging company whatever its name now from further logging permits until harmful practices are changed.

General narrative outcome for invasive species:

Comment: The noxious weed board of Island County was advised years ago that a member of the fireweed was taking over the wetlands at Keystone and did nothing. Now the invasion is not just a few hundred square feet but acres and acres of invasive weeds that are choking out native species. Marianne Edain of Whidbey Environmental Action Network –WEAN, made that call. She has kept track of Rare Native Species in Island County and Washington State and would be an excellent resource for restoration as she also has Frosty Hollow Native Seed Bank. wean@wean.org

A.2.4. Goal: Puget Sound marine and fresh water are clean.

Potential benchmarks for Water Quality Outcome1

Comment: On “Tissue contaminant levels in marine mammals…..” testing for the presence of “Gender Bender” chemicals is critical as this interferes with reproductive abilities of multiple species. A baseline for the presence of this type of toxic chemical often found as a “Trade Secret” ingredient in Herbicide Formulations, Pesticides, Fungicides, etc. needs to be established in order to establish a benchmark with which to test for throughout time. I’ve submitted a very brief bibliography of peer reviewed scientific studies on this type of chemical. I have not focused on other chemicals that have these same properties such as phalates (plastics) and birth control pill residues that flush into Puget Sound, etc.

I am deeply impressed with the scope and vision of the Preliminary Draft for Restoring Puget Sound Ecosystem Health for Future Generations. I only hope that my comments can help is some small way to examine those parts that I have submitted as needing further study and or implementing processes to involve the public in ownership of the goals.

Documentation that I have requested from Ray Willard at WSDOT should be received by me next week. Additional documentation that I have requested will need to be requested via PDA requests and could take up to six weeks to receive back. I request that I be allowed to submit those portions of my comments as I receive them from WSDOT.

I will also be submitting PDA requests to Department of Agriculture Spartina Program and other divisions and from the Department of Ecology, and Island County Noxious Weed Board and request that I am allowed to submit these additional documents as I receive them. I was informed by Chad Phillips Dept of Ag Spartina Program Director that no compilation of the costs and total amounts of herbicides applied to Washington State waters has been kept. That would mean that no documentation exists that proves that chemical applications have been successful and if that is true a new way of doing Spartina eradiation needs to be created and measured.

It would be interesting to find out the amounts of fertilizers, herbicides, pesticides, fungicides, etc. that have been and are being used by agriculture in the river valleys, stream drainage regions and upland areas of Hood Canal.

I would hope that we could learn from the Chesapeake Bay failure of their restoration plan put into place two decades ago. In the book, “And the Waters turned to blood” by Rodney Barker, many of the challenges and difficulties of the Chesapeake Bay restoration were included. Scientists with the Chesapeake Bay Foundation are excellent resources for learning from their failures that we may avoid them.

I would appreciate being put on your mailing list for updates on the progress of the Puget Sound Partnership. I didn’t learn of the comment period until October 20th so this has been a rushed turn around. With more time I would have had more recommendations for strategies to make the coming process and goals a reality by 2020. I would hope that you would call on me for clarification or expansion of the comments and recommendations I am submitting today.

Download Supporting Documents List submitted with Theresa's comments on October 31, 2006.

A Conservative Activist working for a quality environment for Our Seventh Generation, Theresa Marie Kothari Gandhi, Activist Poet and Ecological Wisdom Advocate, Whidbey Island, WA.

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