The Washington Department of Ecology is updating the North Central Puget Sound (NCPS) Geographic Response Plan (GRP). An important part of the update process was hearing from the people that live, work, and play in the GRP area. To facilitate this, we opened the plan to public comment from September 18th  to October 18th, 2020.
Below, you will find an overview of comments received and Ecology’s response. Ecology appreciates everyone who took the time to provide comments on this GRP. GRPs are improved by this community’s input and we appreciate your ongoing efforts in protecting Washington’s environment. Feel free to reach out to or 360-480-2084 with any questions.

North Central Puget Sound GRP Responsiveness Summary to Comments

Ecology post plans for public review for 30 days. After the 30 day public review period ends, Ecology addresses all comments received. The following is a responsiveness summary to your comments submitted to Ecology.

GRP Section

Public Comment

Ecology Response

General Updating GRPs is a critical, pro-active step in oil spill preparedness and response. Thank you for supporting Ecology’s effort to update Geographic Response Plans in Snohomish County.
General Changing the format of the GRP to a web-based one with downloadable sections and embedded links substantially increases the utility of the document, and facilitates a more effective, timely response, when implementation of the plan is necessary. Thank you for your feedback on the online platform we are migrating to in the upcoming year.
General Revisions of the Site Description and Resources at Risk sections are significant improvements. We greatly appreciate the inclusion of much of the county-specific information that we previously provided in writing during the 2017 Stillaguamish GRP update as well as with those we discussed with you in-person during our meeting last year (Sept.2019). On behalf of Ecology and the Spills Program, I would like to thank the Snohomish Marine Resources Committee for going above and beyond in the review of this GRP. Thanks to your tireless work in preparedness, this plan is clearer and will be more effective in a potential spill.
General Recommend acknowledging and cross-referencing between adjacent GRPs, when applicable, given the hydrologic connectivity of the region, the widespread distribution and mobility of the area’s sensitive natural resources, and the significant importance of the local cultural and economic resources. Such cross-references would allow spill responders to be better informed and potentially help them more effectively minimize regional spill-related impacts. As Ecology moves GRPs to an online platform, there will be cross referencing on the JETTY site that will assist responders in identifying resources at risk across GRP boundaries.
Site Description 2.6 RISK ASSESSMENT 2.6 ? Are other sections numbered? Please check for consistency. This was an error in numbering- the 2.6 has been removed from the GRP.
Site Description Aircraft: The Whidbey Naval Air Station and Payne Paine Field (Everett) … note spelling correction The spelling error has been corrected in the GRP.
Site Description Recreational Boating: Accidents involving recreational watercraft in the planning area have the potential to result in spills of a few gallons of gasoline up to hundreds of gallons of diesel fuel various petroleum products (e.g., gasoline, diesel, lubricants). Thank you for your recommended edits to this paragraph- the sentence has been updated in the GRP and reads much clearer now.
Response Contacts Sheet Thanks for sending the response contact page for the NCPS GRP.  The only addition that I would suggest is to consider  including the Snohomish Conservation District. It works very closely and collaboratively with farmers, agriculture folks, and rural landowners throughout the county and may be a valuable asset to contact in the event of a spill response. Due to the general role of conservation districts, it seems inappropriate to include them in the emergency contacts sheet. However, conservation districts do represent significant economic resources, and their contact information is now included in the economic resources at risk section of the plan.
Non-Floating Oils Response Options Water turbidity The use of the term “sedimentation” in multiple contexts is somewhat inaccurate and misleading. Suggest replacing text with: Turbulence can result in increased sediment loads in the water column that, if entrained with spilled oil, may increase the oil’s density and cause it to submerge or sink. The corresponding section was updated to include the clarifications surrounding sedimentation/turbulence. This change will be made in all GRPs with a corresponding non-floating oil section.
Non-Floating Oils Response Options In the “Conditions And Considerations For Non-Floating Oil” table: If “Open Public Shellfish Harvesting” and “Open Commercial Shellfish Harvesting” include Dungeness crab harvesting, then these categories are present in Port Gardner/Possession Sound. Spawning Areas are present in the Port Gardner/Possession Sound area.
o A Recreational Dive Area is present in Port Gardner/Possession Sound (i.e., the Mukilteo T-dock dive site near the ferry/Silver Cloud Hotel)
Thank you for identifying additional information for this new section of the GRP. The grid has been updated to reflect the information you shared in your comment, except for the open public shellfish harvesting in Port Gardner. I used the Department of Health’s shellfish harvesting map layer to determine the absence or presence of public shell fishing. The only beach mapped in the general area has been closed to public shellfish harvest.
Response Strategies and Priorities Given the significant ecological, tribal, and recreational/economic resources at risk in the Port Susan area, it would be advisable to consider a response strategy for the Kayak Point region of Sector NC-4. Kayak Point County Park is located there. It has a boat ramp and a large parking lot, and could be used as a response staging area. The protection of resources at risk during an oil spill are not limited to what is contained in a Geographic Response Plan. Due to the feasibility and accessibility of the Port Susan area, it would be difficult to design an effective response strategy in this area without better defining a specific resource at risk to protect. However, during a spill ad hoc strategies should and would be developed to keep oil out of Port Susan. Kayak Point County Park will be included in the plan as a more localized staging area for Port Susan, per your comment.
Response Strategies and Priorities There is a NCPS GRP response strategy and option for the railroad crossing of the Stillaguamish River near West Pass (NC-14), but not for the nearby railroad crossing over the Stillaguamish River just west-north-west of Silvana (near the intersection with South Slough). The ecologically and economically sensitive resources in that area, coupled with the large quantities of oil transported by rail in Snohomish County, warrant further consideration for a response plan at this location. COOKS-0.2, within the Stillaguamish River GRP, serves as a collection strategy at the railroad crossing near South Slough. Additionally, downriver of the railroad crossings in this vicinity is HATS-1.75, another collection strategy designed to prevent oil from entering Port Susan. Also, NCPS-15 is a collection strategy downstream of another railroad crossing that would prevent oil from entering Port Susan. No additional GRPs will be added to NCPS at this time, however a note will be added to the Stillaguamish GRP, where the railroad crossings exist, to look into more protection strategies, as needed.
Resources at Risk Eelgrass beds Delete last sentence of the paragraph The kelp beds present near Deception Pass and the northern part of Skagit Bay serve as important fish rearing areas. This sentence was deleted per your request, it duplicates information that is gone into at greater depth in a later paragraph.
Resources at Risk Revise paragraph on kelp beds as follows: Scattered kelp beds occur in the northern portions of the region, near Deception Pass and the northern part of Skagit Bay, as well in the southern portion of the region, near Gedney (Hat) Island. These habitats perform ecological functions similar to eelgrass beds, and serve as important fish rearing areas. The paragraph on kelp beds was revised, per your recommendations.
Resources at Risk Restoration sites are areas where significant efforts have occurred to restore natural functions in a degraded habitat. The missing verb was added to this section.
Resources at Risk Rock reefs Sentence revision: Macro algae, and including kelps, also widely utilize the structure that this type of habitat provides. Addition: The crevices and overhangs associated with these reefs serve as valuable habitat for a wide variety of other species such as crabs, shrimp, octopus, wolf eel, rockfish, cabezon and lingcod. The language in this section was updated to include kelp as a macro algae, thank you for the correction. Additionally, cabezon were added to the list of species in this section.
Resources at Risk Marbled murrelets occur throughout the region, especially near Deception Pass, within Saratoga Passage, and in the southern portion of Port Susan and Port Gardner/Possession Sound. Port Gardner and Possession Sound were added to this section of the plan.
Resources at Risk Small numbers of gray whales are commonly found in Saratoga Passage, and Port Susan, Port Gardner and Possession Sound from spring through late fall. Port Gardner and Possession Sound were added to this section of the plan.
Resources at Risk 8. Old Stillaguamish River Channel: Eelgrass, wetland, salt marsh and slough habitats. Salmonid spawning and rearing habitat. Presence of federally threatened bull trout, Puget Sound Chinook, and Puget Sound steelhead. Waterfowl and shorebird concentrations.). Harbor seals. Leque Island and zis a ba restoration sites. The unnecessary “)” has been removed from the plan.
Resources at Risk 13. Possession Sound, Gedney (Hat) Island and vicinity: Forage fish spawning. Juvenile salmonids and rearing habitat. Dungeness crab and shellfish. Bald eagle nesting and marbled murrelet. Orca, humpback whales, and gray whale feeding area (spring through fall). Possession Sound was added to the title of number 14, and the additional species were updated per your recommendation.
Resources at Risk 14. Cultus Bay: This area is not within the boundary of the NCPS GRP. It is in the adjacent Admiralty Inlet GRP. Recommend deleting from the document’s text and Geographic Areas of Concern Figure 3. A clarifying statement was added to this paragraph, directing the reader to the Admiralty Inlet GRP for more information.
Economic Resources at Risk Please add Edgewater Beach Park and the Mount Baker Terminal Shipping Facility. Both are located in Mukilteo/South Everett and are owned by the Port of Everett (check to see if Mukilteo will be the manager/point of contact for the Edgewater Beach Park as part of the city’s Waterfront Landing Plan/Project currently in progress). Both locations represent economic resources potentially impacted in the event of an oil spill in the area and should be identified in the GRP. Thank you for identifying these additional economic resources at risk for addition in the NCPS GRP. Both Edgewater Park and the Mount Baker Terminal have been added to the economic resources at risk portion of the plan.