October 30, 2000

Tom Fitzsimmons
Department of Ecology
PO Box 47600
Olympia WA 98504-7600

RE: Draft Strategy to Continually Reduce Persistent, Bioaccumulative, Toxic
Chemicals (PBTs) in Washington State

Dear Mr. Fitzsimmons:

Thank you for the opportunity to provide comments on this important issue.

The current draft strategy has a number of good general features: The Washington Environmental Council (WEC) is encouraged by the draft strategy's intention to address cross media and non-point source effects, and to emphasize pollution prevention. We look forward to more concrete details as to how these intentions might be achieved. Further, WEC supports Ecology's contention that industry is not the only source of PBT contamination; that the personal actions of individual citizens can play a significant part in the success or failure of the effort to rid the environment of the state of new PCB releases. WEC supports Ecology's development of a broad educational program to address this issue.

However, the current draft strategy also raises several concerns: 1) The draft strategy correctly recognizes that clean up of historical sources of PBT contamination is an important part of PBT reduction in the environment. Unfortunately, nothing is mentioned about this in the "specific activities" section of the draft strategy. Further, a major loop-hole in the cleanup process remains un-addressed: the off-loading of contaminated material from historic sources into fertilizers, topsoil, and other products. Such off-loading must stop if the state is to have a credible PBT strategy.

2) Industry reduction of PBT production should not be optional, but rather mandatory. Elimination of further production of PBTs is essential, and Ecology needs to make this crystal clear to industry. Ecology regulatory staff is currently working on revisions to important state environmental rules such as water quality standards, Air Operating Permits, and amendments to dangerous waste rules. They are drafting new waste water discharge permits for numerous PBT releasing facilities. This regulatory staff is now in an excellent position to integrate the PBT elimination strategy into the fabric of Ecology's regulation, educate business of the many excellent alternatives to PBT pollutants, and to include regulatory provisions to begin making the high priority goal of elimination of PBTs a reality.

3) The draft strategy is not aggressive enough. Of the 9 chemicals on the "starter list" of the draft strategy, 4 have already been banned from use in the U.S. Further, 20 years are given for the elimination of PBTs "where possible." Twenty years is too long to achieve this goal. WEC supports a shorter timeline for phase-out of production of new PBTs, and suggests that all 27 PBTs which have been identified by Ecology as present in the Washington state environment be put on an initial "list" for eventual elimination.

Thank you for considering our comments.


Joan Crooks
Executive Director
Washington Environmental Council
615 Second Avenue, Suite 380
Seattle, WA 98104