Piling on Puget Sound (Part 3): Comments against cumulative impacts

The treaty tribes in western Washington believe that the Corps’ streamlined nationwide permit system is making it too easy to damage and destroy important nearshore salmon habitat in western Washington. Here’s what Billy Frank, chairman of the Northwest Indian Fisheries Commission, has to say on the topic:

The Corps is encouraging habitat degradation by streamlining the process to allow property owners to build the very same structures that we are working to remove as part of salmon recovery efforts. That puts the federal government at cross purposes, because while the Corps is expediting shoreline modification work with little consideration of their cumulative impacts, federal funds are also being used for bulkhead removal and other nearshore habitat repair work.

While a streamlined process for shoreline modifications might work well in other parts of the country, it is making salmon recovery more difficult in western Washington. This isn’t the Mississippi River or Florida we are talking about. They don’t have salmon. We do, and we need to do everything we can to help them because they are in real trouble. Their habitat is disappearing.

We are asking the federal government to align around salmon recovery. The federal government has a trust responsibility to protect tribal treaty rights. Other federal agencies have been responsive and are also asking the Corps to ensure its actions mesh with salmon recovery efforts. Now is the time for coordination and action on these problems.

If we are going to recover salmon, we have to stop damaging and destroying salmon habitat. The Clean Water Act law is clear. By continuing to issue these types of permits for shoreline changes, the Corps is saying that these projects aren’t causing harm, and that’s just not true. We can’t recover salmon if we keep losing and damaging salmon habitat.

Here’s a recent letter  from the Northwest Indian Fisheries Commission to the Corps.
The tribes are calling on the Corps to change its streamlined approval process for shoreline changes to an individual permit process that would take into account the special needs of salmon and the loss of nearshore habitat in the state’s marine environment.

The tribes aren’t asking the Corps to stop issuing permits for shoreline work nationwide, but rather for the Seattle District Office to switch to an individual permit system that acknowledges the need to protect and restore salmon habitat in western Washington.

The tribes are not alone in their call for reform. Here are excerpts from letters that federal and state natural resources management agencies have sent to the Corps on the issue:

Will Stelle, regional director of NOAA Fisheries:

The continued steady and substantial loss of shoreline aquatic functions directly attributable to the “hardening” of shoreline areas through the placement of fill, rock, or other structures has a direct and considerable negative impact on the long-term survival and recovery of these [ESA] listed fish populations [in Western Washington].

Kate Kelly, Environmental Protection Agency, Office of Ecosystems, Tribal & Public Affairs:

In particular, EPA has significant concerns about cumulative impacts to Puget Sound as we indicated in our December 17, 2011 letter to you. We request your support for strong and proactive regional conditions protective of Puget Sound marine and estuarine waters.

Ken Berg, manager, Washington Fish and Wildlife Office, US Fish and Wildlife Service:

In many cases we have recommended that actions be submitted through the individual permit process rather than the NWP process or that specific resources be excluded from the NWP process. These recommendations reflect the Service’s serious concern over the potentially significant environmental effects of the NWP program on listed and other fish and wildlife resources…

Steve Landino, Washington State Habitat Director, National Marine Fisheries Service:

Given the importance of the Puget Sound nearshore for juvenile salmonids, the extent of shoreline armoring already present in Puget Sound, the cumulative impacts of small-scale armoring activities, and the significant adverse effects resulting from shoreline armoring on salmonids and their prey, NMFS believes it appropriate to have regional conditions that restrict or prohibit the use of NWPs in Puget Sound.