Puget Soundkeeper (“PSK”) was founded in 1984 as a grassroots organization focused on protecting and preserving Puget Sound. In its first major legal action, PSK successfully fought to require secondary treatment of sewage—a process that prepares wastewater effluent for safe discharge or further treatment—at King County’s West Point Wastewater Treatment Plant. 

Today, PSK is continuing its legacy of fighting for better treatment of wastewater discharged to Puget Sound from sewage facilities, generally referred to as wastewater treatment plants (“WWTPs”). The discharge of excess nutrients—nitrogen and phosphorus—to Puget Sound from WWTPs is causing low oxygen levels in Puget Sound and the Salish Sea.  

Now, the communities surrounding Puget Sound have a chance to do something about this present and growing problem that is harming Puget Sound and the life in it. After decades of delay, we have the chance to ensure that dozens of these facilities that discharge directly into Puget Sound are finally bound by permit terms that protect water quality by reducing excess nutrient discharges.   

Excess nutrient discharge “increases algae and can lead to low dissolved oxygen in the water. This is a serious problem for fish, animals that rely on fish such as orcas, and the health of Puget Sound . . . [t]oo many nutrients, mainly nitrogen, result in excessive algal growth because nutrients act like fertilizer for algae and aquatic plants. When these algae and plants die, their decomposition uses up oxygen that marine animals need to survive. This can especially be a problem in shallow inlet or bays and throw the health of Puget Sound off balance.”

Washington State Department of Ecology 

On its website, Ecology identifies negative impacts of excess nutrient discharges including low dissolved oxygen, acidified water, low biodiversity, non-nutritious food web, nuisance and/or toxic algae outbreaks, toxic shellfish outbreaks, and less healthy food for salmon and orcas. Moreover, warming waters from climate change will exacerbate these problems, especially the potential increase of toxic algae and shellfish outbreaks. 

Under the federal Clean Water Act, Ecology is required to regulate discharges from WWTPs. In 1992, Ecology placed portions of Puget Sound on its list of impaired waters—those that fail to meet baseline water quality standards—for failing to meet dissolved oxygen water quality standards, which, even then, Ecology knew was likely the result of excess nutrient discharges. Nothing changed for polluters except for increasing pollution. In 2014, Ecology identified 136 “impaired” areas for dissolved oxygen in the Salish Sea. Still nothing changed for polluters. Then, again, in 2019, Ecology published the Bounding Scenarios Report, which evaluated the impact of human nutrient sources on dissolved oxygen across a range of modeled years using the Salish Sea Model. In that report Ecology noted that “[a]pproximately 20% of Puget Sound does not meet [dissolved oxygen] standards,” “[d]omestic marine WWTPs (those located in Washington State and discharging into Puget Sound) were the largest contributor of human-sourced nitrogen loading to the Sound,” and that “discharges from domestic marine WWTPs can affect [dissolved oxygen] concentrations far from where discharges occur.”  

Ecology concluded seven years ago, in 2019, that “to restore water quality in Puget Sound, wastewater treatment plants and watersheds draining to Puget Sound will need to significantly reduce their nitrogen loading in the coming years.” Further, Ecology noted that “control of total inorganic nitrogen is the appropriate first step to address nutrient pollution from domestic WWTPs as inorganic nitrogen (the sum of nitrate-nitrite and ammonia) is the form of nitrogen more available for algal growth driving eutrophication and the existing [dissolved oxygen] impairments.”   

Yet, to date, Ecology has not included any nutrient effluent limits in 57 of the 58 WWTP permits discharging to Puget Sound (the sole exception being the Lott Wastewater Treatment Plant in Olympia). Washington is far behind the curve for control and treatment of these pollutants in our wastewater with terrible results for Puget Sound. 

Across the United States, state and federal water quality agencies like the EPA and Ecology have been limiting nutrient loads and requiring WWTPs to install nutrient treatment technologies for decades—from New York City to the Chesapeake Bay, San Francisco Bay, and throughout the Great Lakes. Puget Sound is among the last major watershed in the nation where these controls have not yet been rolled out.

View of Puget Sound

PSK is once again taking on the fight to advocate for necessary conditions in these WWTP permits to protect water quality in Puget Sound. PSK is commenting on every WWTP draft permit or permit modification as they are released by Ecology. The goal of PSK’s comments is to advocate for the inclusion of nutrient effluent limits—limits that are technologically sound, available, and in use throughout the nation—that will result in the control and reduction of excess nutrient discharges in the Sound. We agree with Ecology that “that to restore water quality in Puget Sound, marine point sources and nutrient sources within watersheds draining to Puget Sound will need to significantly reduce their nutrient loading in the coming years,” which is why we are urging Ecology to include permit requirements that actually reduce nutrient loading from WWTPs discharging to the Sound—not just allow the grossly polluted status quo to continue. 

If you want to submit a comment on any of these permits, you can visit Ecology’s Public Input & Events webpage for a list of open comment periods. A list of the WWTPs that Ecology is issuing these permit or permit modifications for can be found on Ecology’s website

If you are interested in reading PSK’s comments on the draft permits released for public comment, here is what we are saying: 

For more information from Ecology on the dissolved oxygen and excess nutrient discharges problem in Puget Sound, you can visit their websites, below: