On March 23, the Department of Ecology will conclude the public comment period for a multi-year process that claims to be aimed at reducing the toxic exposure of fish consumers in Washington State. Ecology’s proposal shuffles the numbers, but essentially leaves pollution discharge standards at their current levels.

For years, Washington has had some of the lowest water quality standards in the nation. These standards establish approved levels for a laundry list of pollutants, and are used to determine pollution permit limits for industry and businesses. They are partly based on Fish Consumption Rate (FCR), a measure of how much fish people in our state eat on a daily basis. The EPA encourages states to consider their most sensitive populations when setting this number. However, the FCR is not the only number that influences water quality calculations. Other inputs include allowable cancer risk, drinking water intake, and average body weight.

(Confused yet? Maybe our infographic will help.) 

Washington’s water quality standards were previously based on a very low FCR. Despite having large amounts of shoreline along Puget Sound, the Pacific Ocean and the Columbia River and access to a large variety of fresh, local fish and shellfish, Washington’s fish consumption rate was previously set at 6.5 grams per day. (A Department of Ecology report compiled in 2012 revealed that the average consumption for the general population averages 19-56 grams/day, and tribal members may eat up to 797 grams/day.)

Salmon on the grill. Under the old water quality standards, the fish consumption rate was set at only 6.5 grams a day - about one bite of fish.

Governor Inslee and the Department of Ecology have put out a draft proposal for new water quality standards. The new proposal raises FCR to 175 grams per day. But it also raises allowable cancer risk from one in a million to one in a hundred thousand. Taken together, the two changes counterbalance each other. The levels of many toxic chemicals, including PCBs, mercury and arsenic, would remain the same under the new rules, and Ecology’s own economic impact analysis found that the new rules would cost existing businesses nothing, because the minor changes to allowable pollutant levels will not require them to update their water treatment systems.

This is an environmental justice issue. We know from Ecology’s own research that the groups with the highest fish consumption are tribal members, Asian-Pacific Islanders, and commercial and recreational fishermen. These sensitive populations cannot be considered as outliers. They have equal protection under the Clean Water Act, and therefore they must set the bar for how protective our new standards should be. This could be achieved by using the 175 grams/day FCR endorsed by the tribes WITHOUT also raising allowable cancer risk.

Fishing on the Duwamish River. Many communities depend on subsistence fishing, even when water quality is poor.


This is a public health issue. Cancer is one of the leading causes of death in Washington State, and there should be no allowance for more cancer in our communities.

This is an economic issue. Washington State’s maritime industry is a crucial part of our economy, generating $30 billion in revenue each year and about 148,000 jobs. Fishing and seafood processing account for nearly 60 percent of that revenue, according to a 2013 report supported by the Puget Sound Regional Council and the Economic Development Council of Seattle. This draft plan would place zero burden on polluters and all of the burden on local commercial and recreational fishermen, their customers, families, and fish consumers. Furthermore, the cleanup costs – which are likely to be much higher than preventative treatment of wastewater and stormwater – will fall to taxpayers. As Lorraine Loomis, chair of the Northwest Indian Fisheries Commission, wrote in a recent column: “An economy built on pollution cannot be sustained.”

This is not progress. Keeping pollution at current levels that have been demonstrated to result in fish that are unsafe to eat in normal amounts is completely contrary to the point of revising water quality standards for toxins and flies in the face of the requirements of the Clean Water Act.

The public comment period on the new Water Quality Standards remains open until March 23.

Public hearings will be held in Spokane, Yakima and Lacey in early March. Details are on the Department of Ecology website.


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