MEMORANDUM TO: Puget Sound Partnership FROM: Bill Wynn and Elspeth Hilton RE: Suggested policy options to prevent hypoxia in Hood Canal DATE: June 6th, 2011 Executive Summary The following memo represents the final component of our analysis of policy solutions Puget Sound Partnership should consider supporting for Hood Canal. In this memo we will discuss the causes of hypoxia in Hood Canal, possible solutions to this problem, criterion for which solutions will be judged, and the key tradeoffs between options. We conclude the memo with recommendations for your consideration. Hood Canal, a saltwater fjord in Washington State, experiences hypoxia (low dissolved oxygen) events, which result in a decline in the health of the plants and animals within the waterway. The physical characteristics of Hood Canal make it difficult for water to circulate effectively. Run-off provides nutrients conducive to excessive algae growth which results in lower dissolved oxygen. Over the past several years hypoxia events appear to be occurring more frequently, with greater severity, and over larger areas. Dissolved oxygen dropped to critical levels in 2003, 2006, and 2010 culminating in massive die-offs of economically important fisheries and other marine life. While the causes of low oxygen conditions in Hood Canal are complex, research suggests human impacts – such as sewage wastewater and storm water runoff - likely exacerbate the condition. Reducing runoff that contains nitrogen is the key to improving dissolved oxygen levels and thus improving the health of Hood Canal. Policy options to reduce unhealthy runoff include supporting existing efforts to improve wastewater treatment plants, mandating the installation of nitrogen removing septic tanks in individual residences, implementing stricter land use policies in order to reduce storm water runoff and providing incentives for filtering shellfish aquaculture. A media campaign and ongoing monitoring should be included in any solution. Key criteria for determining the most appropriate solution includes impact on hypoxia, cost, political feasibility and adaptability In considering the tradeoffs between options, we find that the status quo while politically feasible would not make a sufficient enough impact on hypoxia and nitrogen levels to be considered as a sole option. Improvements to septic systems, while creating the greatest impact on nitrogen and hypoxia, could be hampered by political opposition on the grounds of costs to private households. Policies aimed at reducing storm water runoff, while fairly inexpensive and politically feasible, do not impact nitrogen significantly. Finally, off-shore aquaculture may produce moderate reductions at a reasonable cost, however concerns over the siting of such facilities reduces the overall feasibility of this option. 1 The result of this analysis is a recommendation that Puget Sound Partnership advocate on behalf of improved septic systems. While this option suffers from both political and cost obstacles, the effectiveness of this solution in creating a healthier Hood Canal merits serious consideration. Background Hood Canal is a 60-mile long saltwater fjord located between Kitsap and Mason Counties (Appendix A) in Washington State. The area is home to over 50,000 residents, with most living in near proximity to the 212 miles of shoreline. Sources of the Problem: Natural Influences Two factors combine to contribute to low oxygen in marine systems: lack of seawater circulation and unbalanced organic production and respiration. Both of these conditions are present at Hood Canal, resulting in naturally-occurring low dissolved oxygen concentrations. Lack of Seawater Movement and Circulation Seawater has a difficult time moving and circulating in Hood Canal because of the long shape and topography of the canal, resulting in lower dissolved oxygen concentrations relative to the distance from the open ocean. In addition, a prominent sill (shallow area) at the mouth of the canal prevents seawater from horizontally mixing (“Science Primer,” n.d.). Another important obstacle to seawater movement is water stratification. When fresh water flows into the salt water canal the warmer and less dense fresh water tends to sit like oil on top of the colder and denser salt water. This acts as a barrier to vertical mixing of water. The result is highly stratified sea water, with higher oxygen concentrations near the surface and lower concentrations below (Newton, n.d.). Organic Production and Respiration In the top levels of Hood Canal phytoplankton and algae grow as a result of the abundant nutrients and organic matter flowing in from tributaries. However, these algae and phytoplankton eventually die and sink to the bottom where they undergo decomposition, using up oxygen in the process. Because of the lack of seawater circulation this deeper layer is rarely exposed to oxygenated water, and thus becomes oxygen deficient (“Science Primer,” n.d.). The strong natural tendency of Hood Canal waters to become both horizontally and vertically stratified along with slow circulation and a high incoming organic load all contribute to a naturally low level of dissolved oxygen. Sources of the Problem: Human Influences 2 While Hood Canal’s natural attributes contribute to lower dissolved oxygen concentrations, it appears that human influences play an exacerbating role by adding excess nutrients, especially nitrogen. The addition of nitrogen results in stimulated algae growth which eventually decomposes on the sea floor, consuming oxygen in the process (“Background Information,” 2005). Sewage is the most significant human created nitrogen contributor to hypoxia in Hood Canal (Appendix B). During summer months up to 20% of the nitrogen in Southern Hood Canal may come from discharge from the on-site sewage systems (OSS or septic system) of over 24,000 households in the region (Dunagan, Christopher, 2011). Virtually all of the septic systems in Hood Canal are not designed to remove nitrogen and this source alone accounts for between 39 and 241 tons of nitrogen in Hood Canal (Fegergren & Criss, 2004). Storm water run-off is also a significant contributor of nitrogen and is largely a result of development. Impervious surfaces do not allow nitrogen to be remediated before discharge into the canal. This source accounts for between 12 and 24 tons of nitrogen (Fegergren & Criss, 2004). Additional minor human sources of nitrogen include pet waste, agricultural runoff, and discarded salmon carcasses. When oxygen levels in Hood Canal are particularly low due to natural factors, the added load of nitrogen from human sources may push the ecosystem over a threshold into hypoxia. Symptoms and Effects When oxygen levels fall to dangerous levels in Hood Canal, massive biota die-offs are the result. As oxygen falls to below 5 mg/L, fish and invertebrates begin to show signs of stress. As the oxygen level falls to between 1-2 mg/L, organisms experience severe stress or die (Hull & Bryan, 2005). These events tend to impact bottom-dwelling creatures in particular, including lingcod, rockfish, wolf eels, and spotted prawns. Research suggest average dissolved oxygen concentrations during the 1990’s and 2000’s are lower than the historical average (Roberts et al., 2004). There have been a number of prominent hypoxia events in the last several years, in 2002, 2003, 2006, and a smaller event in 2010, resulting in massive die-offs of biota. While southern Hood Canal, Lynch Cove in particular, is especially prone to hypoxia events due to its distance from the open ocean; in recent years low dissolved oxygen has become a problem further north as well. Policy Context Several constituencies are affected by the problem of hypoxia in Hood Canal: Nature tourism - As wildlife beneath the waters of Hood Canal is a primary recreational draw to the area, this industry is uniquely impacted by hypoxia. Hood Canal, with its protected waters 3 and decent winter weather is a major regional destination for scuba divers, who are likely to spend over $150 day in local communities (Gibilisco & Rickert, 2004). Recreational and commercial fishing - Hood Canal is home to recreational and commercial fishing for a variety of species. Salmon and shellfish are both vital to the local economy, and the status of each species is at risk with declining levels of dissolved oxygen. Previously, the fishery for lingcod and rockfish was a popular attraction, until being closed in 2003. Local industries and communities - Solutions to the problem of low dissolved oxygen could have impacts on local industries and communities if they are forced to change practices both on the municipality and private household level. What has been done about hypoxia in Hood Canal so far? Monitoring - Funds secured by Congressman Norm Dicks in 2003 established the Hood Canal Dissolved Oxygen Program-Integrated Assessment Modeling study. This research group has researched and published extensively on the causes of hypoxia in Hood Canal. Education – The Hood Canal Coordinating Council utilizes a variety of tools for education and outreach. Programs include the Community Nearshore Restoration Program and the Marine Riparian Initiative, both of which include education workshops and activities that spread awareness and encourage actions such as planting native species along shorelines. The Puget Sound Partnership also conducts outreach throughout Western Washington about ways individuals can reduce their impact on Puget Sound. Legislation - A bill was introduced in 2008 by Rep. Bill Eickmeyer (D-Belfair) requiring new houses to be outfitted with special nitrogen-reducing OSS (Dunagan, 2008). It was blocked in the senate. Regulation - After the 2003 fish kill, WDFW temporarily closed the bottom fish fishery (lingcod, rockfish) to help stocks recover. It has remained closed since. Policy Options Several options are available to policy-makers in confronting the hypoxia threat to Hood Canal. As nitrogen inputs are directly related to algal growth and are the sole controllable source of oxygen debt, any corrective policy action must be focused on reducing and/or mitigating the effect of nitrogen in Hood Canal. Additionally, we feel the following activities should accompany all policy options: Media and outreach campaign - Educational outreach and an accompanying media campaign should be part of any policy solution. While the Puget Sound Partnership has already done an extensive education campaign using internet and print media and community outreach to inform 4 residents about Puget Sound in general (Puget Sound Partnership, 2009), targeting Hood Canal residents with a campaign about the causes, effects, and solutions to hypoxia is of the utmost importance for successful implementation. Additionally, this media campaign should address other small but important steps individuals can take to reduce the amount of nitrogen that ends up in Hood Canal. Continued monitoring - Because the key outcome of any adopted solution is the reduction of nitrogen and therefore an improvement in the concentration of dissolved oxygen in the canal, monitoring of DO and nitrogen inputs should be continued in all cases. This is especially important as improved research and monitoring results are essential in informing short-term policy decisions (such as fishery closures), refining existing policies, and informing new corrective actions. Continuing to involve citizens in monitoring efforts also benefits future policy decisions by involving citizen stakeholders in the process of defining and addressing the problem. Option # 1: Status quo The first option is to maintain and support existing efforts including centralized sewage system upgrades, dissolved oxygen monitoring and community outreach. The development of a nitrogen-filtering wastewater treatment facility is in progress in Belfair in southern Hood Canal, which will update the filtering technology to reduce nitrogen in output and will direct the discharge away from Hood Canal into a forested area, creating a natural filter for the remaining nitrogen. Option #2: Comprehensive improvements for residential septic systems This comprehensive policy option aims to reduce the discharge of nitrogen from private household septic systems by mandating the installation of nitrogen-filtering septic systems in new constructions (and for replacements for failed tanks) for all homes within 1500 feet of Hood Canal and 250 feet of its tributaries. Nitrogen reducing septic systems can effectively filter out between 60-97% of the nitrogen from onsite septic systems. Currently, several OSS manufacturers offer this type of filtering at a cost of between $7500-$15,000 for installation and five years of maintenance (“Maryland’s Nitrogen-Reducing Septic Upgrade Program,” n.d.). A comprehensive solution would introduce an annual state nitrogen tax of $500 for those private homeowners and businesses that live within 1500 feet of the shore or 250 feet of a tributary and do not have a nitrogen-filtering septic tank. Annual collections of this tax (approximately $12 million) would be invested in a “Hood Canal Restoration” fund and proceeds used as cash incentives for septic system upgrades, replacements and new construction installations, and incentives for development of community septic systems. Option #3: Reducing storm water runoff 5 This option would focus on reducing nitrogen-heavy storm water runoff through incentives and a storm water fee. First, local municipalities would create an incentive for low impact development (LID) by expediting permit applications for LID projects. Second, local municipalities would charge an annual storm water utility fee that would be calculated based on a per unit basis. Each ESU (Equivalent Stormwater Unit) is 1,530 square feet of impervious area on a property and fee per unit ranges from $5 to $15 depending on the level of imperviousness (City of Minneapolis, 2011). Reduction in impervious surfaces would result in a reduction in the fee and the square footage of converted pervious surfaces would act as credit (up to 50% of the fee), providing an incentive to property owners to improve their pervious to impervious surface ratio (EPA, 2010). Examples of ways residents can earn credit include creating rain gardens and vegetated rooftops, planting trees and shrubs and the use of permeable pavement, which help to filter nutrients and pollutants and reduce overall storm water runoff (EPA, 2007a). Waterfront homeowners who implement a buffer zone (strips of shrubs and trees) between their home and the shoreline would be eligible for additional credit (up to 25% more) with the highest credit given to those that implement a thick (27 feet) strip of trees. Fees collected would cover regulation and assessment, with any additional funds paying for education and outreach efforts. Option #4: Open public waters for shellfish aquaculture This option would open certain public waters for shellfish aquaculture in Hood Canal. Bivalve mollusks are efficient filter feeders and remove excess nutrients from coastal marine waters. Experiments in Swedish fjords similar in shape and oxygen-depletion as Hood Canal have shown that off-bottom mussel farms can significantly reduce oxygen demand (Haamer, 1996). Hood Canal already supports a large number of tidal shellfish, however only geoducks exist outside of the relatively narrow tidal range. Creating tax incentives for off-shore long line mussel rafts in the southern reaches of the canal could mitigate the effects of nitrogen inputs on the canal while providing a valuable economic resource for tribal populations and entrepreneurs. An operation producing a biennial harvest of 200 tons of mussels could filter approximately 2000kg of nitrogen at a cost of $14,000-$25,000 in materials (Haamer, 1996). Opening public waters to these types of operations through a permit lottery will help stimulate the growth of this industry in southern Hood Canal. Based on the available water surface area and cash incentive, we estimate southern Hood Canal could support between 10 operations of this kind. Evaluative Criteria Evaluation of the policy options will be based on the following broad criteria: Impact on hypoxia - The key policy outcome of any adopted option will be the reduction of hypoxic conditions in Hood Canal brought about by a reduction or mitigation of nitrogen inputs. Using current nitrogen and DO levels as a baseline, we will evaluate impact by estimating reductions in nitrogen inputs (measured per ton) and projected usefulness of each solution in 6 impacting hypoxia on a wider scale. Additionally, we will evaluate the certainty of each option working to lower DO as intended. Cost - Possible solutions to hypoxia in Hood Canal add a financial burden to local municipalities, businesses and individual home owners. Providing a solution that is not affordable for a municipality will result in a failure to implement and high costs to individuals will cause resistance and backlash, so it is important that the final solution is cost effective for all parties. We will evaluate both the private and public costs of each solution to determine the overall financial impact of each solution. We will provide figures based on kilograms of nitrogen reduced, as a way to measure cost effectiveness of each solution in relative terms. Feasibility – Impact and cost will make little difference if a solution is not able to gain support, financial backing, the ability to implement or the ability to adapt, so we have included three aspects of feasibility in our criteria: political feasibility, physical feasibility and adaptability. We will measure political feasibility by evaluating the type of support needed and the ease of gaining such support. Physical feasibility refers to the ability of the solution to be implemented in the ideal location. This includes assessing amount of available land and appropriate space. Lastly, it is important that the solution be able to adapt to unforeseen circumstances in order to ensure sustainability of the program and provide long term results. We will evaluate each solution’s ability to adapt based on the flexibility and comprehensiveness of the solution. Analysis: Trade-offs and Considerations Our analysis of each option in relation to evaluative criteria provided no clearly superior alternative, and thus any consideration of a solution will involve significant tradeoffs. These tradeoffs are presented in Appendix C in the form of a decision matrix. Option # 1: Status quo While an important first step in creating awareness about the effects of nitrogen on Hood Canal and reducing those inputs, we feel that the current efforts being made are not substantial enough. The high costs of creating a new facility at Belfair are not paired with high impact and could be better spent making comprehensive changes to areas with higher residential density. Criteria 1 - Impact: The improvements to the Belfair Wastewater Treatment Plant will serve 1500 households and is expected to reduce nitrogen inputs by 1 ton each year (a reduction of .67 kg per household). The reduction in inputs is substantial for the 1500 households but with septic inputs currently estimated in the range of hundreds of tons, 5 tons is quite minimal. The certainty of the impact is high as the technology being introduced at Belfair has been shown to be highly effective in other locations. However the usefulness of the Belfair project in making impacts on 7 hypoxia is quite low, as the treatment plant can only treat sewage in the confined area around Belfair. In summary, impacts for this option are certain but low. Criteria 2 - Cost: Public and private costs for this option are high up front but due to the length of time the impacts will last (25-50 years), costs are reduced as time goes on. The Belfair project cost $40,000,000 - the majority of which was funded by the State of Washington – a cost of $8,000 per kg of nitrogen reduced. This is the highest cost per kg of nitrogen reduced of all four options. Private costs include a one-time cost of $10,000 for each household to hook up to the new system – loan assistance available through a state program – and residents can expect to pay an additional $90-$100 per month to pay for operating the new plant, a cost of $3,324/kg of nitrogen reduced (Dunagan, 2011). Monitoring and outreach is partially funded by various grants but much of it is done by volunteers. In summary, costs for the status quo are extremely high. Criteria 3 - Feasibility: The construction and funding of the Belfair project is already underway, making feasibility a non-issue. Capacity for the Belfair plant is able to adjust to a small change in population, but the plant is a permanent fixture that will be unable to adapt to large changes. In summary, the feasibility of the status quo is high but adaptability is low. Option # 2: Comprehensive Septic Improvements Comprehensive septic improvements, although quite expensive to implement and facing significant political opposition, provides the greatest positive impact on hypoxia in Hood Canal. Its adoption may be an appealing option if the financing for septic tank price mitigation can be implemented effectively and equitably. Criteria 1 - Impact: Onsite septic systems represent the largest source of nitrogen to Hood Canal, thus mandating the installation of nitrogen-filtering septic systems provide significantly greater nitrogen reduction than alternatives (over 260 tons at 35% uptake over five years, over three times greater reductions than any alternative). This is the greatest advantage of septic improvements. Additionally, the usefulness of these nitrogen reductions in reducing hypoxia is extremely high, the policy would be region-wide, nitrogen reductions would carry through year-round, and the solution addresses the largest source of nitrogen. Also, the certainty of this solution, if implemented properly, is very high. Maryland has enacted similar laws requiring the use of such nitrogen-filtering technology and shown positive impacts in Chesapeake Bay (“Maryland’s Nitrogen-Reducing Septic Upgrade Program,” n.d.). In summary, this option is very effective at reducing nitrogen. 8 Criteria 2 - Cost: Implementing a comprehensive overhaul of septic systems will be very costly, especially for private households. The upfront cost of the new tank is estimated at $7500, with maintenance and operation the total five year cost is $8750. In order to encourage people to take on this not insignificant cost, a nitrogen tax will be put in place at a rate of $500 annually for non-compliance households. These funds would be invested in a restoration fund, whose proceeds could be used as price mitigation for the purchase of the tanks. This substantial private cost for both compliance and non-compliance households results in a high cost per kg of nitrogen reduced: $280. It should be noted though, that this cost should be expected to lower over the useful lifespan of the tank (at least 25 years). Another feature of this tax and incentive system is that costs are not equally distributed, resulting in high initial costs for compliance households and even higher costs over the long term for households that wait. In order to mitigate this effect, the state could implement a financing program or seek federal grants to assist lower income households. The particulars of such a funding mechanism go beyond the scope of this paper. In summary, this option is very expensive, though there may be significant opportunity in achieving cost reductions for private households. Criteria 3 - Feasibility: The current political and financial climate across the state makes the feasibility of this option seem quite weak. In particular, recent support for initiatives that limit the state’s ability to levy new taxes would seem to indicate little chance for the passage of this regulation. Despite this sentiment, a similarly structured bill nearly became law in 2008, passing unanimously in the house before being blocked in the state senate (Dunagan, 2008). Also, due to widespread education campaigns and the highly visible nature of the problem, citizens around Hood Canal have expressed support for comprehensive solutions. Septic system improvements are entirely physically feasible: nearly all households currently have septic systems and the existing infrastructure of connections and drain fields will be compatible with the new septic tanks. Additionally, this option would be very adaptable: tax rates could fluctuate depending on demand and the state of hypoxia in Hood Canal, while the financing and investment options from the nitrogen tax could be changed according to need. In summary, this option is moderately feasible as it faces significant political opposition, but favorable infrastructural conditions and high adaptability potential in response to changes in the political and natural environment. Option # 3: Reducing Storm Water Runoff While incentives for low-impact development are easy to implement and low cost, the results do not produce nearly as significant an impact on nitrogen as the proposed comprehensive septic improvements. While a strong consideration for improving green development, the impact on nitrogen is not great enough to merit the focus of an advocacy campaign for reducing nitrogen. 9 Criteria 1 - Impact: Low-impact development reduces nitrogen inputs by up to 10% during regular rainfall and by 85% during heavy storms (Green Values, 2009), which is when most nitrogen enters waterways. Buffer zones typically reduce nitrogen inputs by 85% although wide strips of trees reduce up to 99% of nitrogen (Straughan, 2003). Using an assumption that 35% of households will implement low impact development and buffer zone features, this option is expected to reduce at least 35 tons of nitrogen input over five years, which is 2.8 kg per household. LID is effective year round, though heavy storms occur most often in the winter and spring so the usefulness of LID on hypoxia is slightly lower (algae growth is at its peak in the summer). Though the effectiveness of LID has been proven, implementation of LID is dependent on individual initiative and the incentives provided will have varying effects. In summary, the impact of reducing storm water runoff is moderate. Criteria 2 - Cost: The cost of this option is low and will create substantial revenue. Giving priority to permits for LID has no cost, just a change in behavior, and implementing a storm water utility fee will cost about $75,000, or the price of 1.5 FTE at $50,000 per employee. Employees will be needed to do the initial assessment of property size and imperviousness and to do conduct ongoing facilitation and regulation of the fee. Assuming the average household has two Equivalent Storm Units (ESU’s) at a conservative estimate of low - moderate imperviousness (about $8) annual costs will be $16. Expected revenue from the storm water utility fee, adjusting for an expected 35% of households receiving credits, is just under $500,000 annually, or $81/kg of nitrogen reduced. Since the annual cost of the fee is just $75,000 and annual revenue is expected to be $500,000, there will be substantial funds leftover for education and outreach as well as room for adjustments to the rate at which behavior changes. Construction costs of LID materials are less expensive than traditional materials the majority of the time, resulting in a cost savings. For existing structures, implementation of new LID features such as trees, rain gardens and vegetated rooftops will cost an average of $1,000 in initial costs and a $50 annual maintenance cost (Green Values, 2009). The cost of construction plus the annual utility fee is about $1,500 over five years or about $450/kg of nitrogen reduced. In summary, costs per kg of nitrogen reduced are moderate. Criteria 3 -Feasibility: Implementing a storm water utility fee is a local issue which raises political feasibility and the logistics of a fee rather than a tax is likely to receive less resistance. The added economic benefit of the revenue from fees also raises the likelihood of local approval. There are a variety of ways to implement LID depending on whether the structure is in construction or already exists. The targeted region is mostly low-density which means most homes have a yard that could be altered to include more shrubs, trees and native plants. 10 Replacing traditional construction materials with LID materials during the building phase is easy to do and will result in a reduction of building and maintenance costs. The fee structure of the utility fee is very easy to adjust and therefore can respond easily to changes to the economy, community density or political ideology while still covering the costs of running the program and maintaining extra revenue for variable levels of education and outreach. Overall, feasibility of reducing storm water runoff through incentives is high. Option # 4: Shellfish Permitting off-shore aquaculture would make an immediate impact on nitrogen levels at a reasonable cost, even generating a profit over time for efficient operators. However, significant concerns about the long-term ability to site and expand operations reduce the attractiveness of this option. Criteria 1 - Impact: By allowing the operation of ten off-shore long-line mussel farms over five years, reductions of approximately 57 tons of nitrogen could be reached (Haamer, 1996). This represents a moderate amount of reductions in comparison to the other options listed. The usefulness of this option in creating reductions in hypoxia is moderate: while mussel farms would reduce nitrogen year round, the impact would be confined to the immediate area around the farms. Additionally, as an option that attempts to mitigate the effects of pollution rather than prevent it, offshore aquaculture’s nitrogen reductions are fixed and would decrease as a proportion of total nitrogen released as population increases. Also, mussel farming as a tool for nitrogen remediation has never been employed outside experimental uses in Sweden, leading to significant uncertainty over the long-term sustainability and impact. There could also be additional secondary negative impacts on hypoxia caused by the operation of such facilities, primarily through the accumulation of waste products from the mussels. In summary, although total initial impact is moderate at roughly 57 tons of nitrogen remediated, the long-term usefulness and certainty of this option is suspect, resulting in low overall impact. Criteria 2 - Cost: As a private enterprise taking place on leased open waters, the costs of this option are relatively low. Initial estimates indicate an annual cost of $21,000 to operate a single farm. Including public costs for enforcement and cleanup assistance result in a gross cost of $21.30 per kg of nitrogen mitigated. The private value of the mussels on the seafood market would reduce the costs further and provide an additional incentive for operators to drive costs downward. At current market prices each operation could generate a profit of $24,000. In summary, costs for this option are relatively low, and over time may produce a net benefit to operators of these farms. 11 Criteria 3 -Feasibility: Because this option would require very little public expenditure and would take advantage of operators profit motive to drive costs down, there would be little opposition on the grounds of costs to taxpayers. However, it is expected that significant political opposition from homeowners and waterfront communities over the siting of mussel farms could derail any efforts to implement this option. Additionally, due to boat traffic, the shape of the canal, and the localized nature of nitrogen inputs, there are limited locations an off-shore farm could be sited. Finally, the adaptability of such an option is moderate: while the farms could be easily constructed and deconstructed, the limited area for operation prevents further expansion of farms to respond to increased nitrogen levels over time. In summary, while this option would not result in new costs or significant expenditures for the state and taxpayers, political and practical concerns over siting reduces the overall feasibility of this option. Recommendation As hypoxic kill-off events in Hood Canal occur with greater frequency it is vital that actions are taken to reduce the amount of nitrogen introduced by human activity. If the region fails to move forward with a plan that reduces the amount of nitrogen that enters the water, Hood Canal will continue to experience hypoxia events that cause a loss of life and degrades the ecosystem below the water and the economies of the communities that surround it. We have analyzed the current policy context and the best available options for reducing nitrogen inputs to Hood Canal in an effort to provide you, the Puget Sound Partnership, with the information necessary to advocate for an action plan that will create the positive outcomes we have outlined above. Based on our analysis of each option in relation to the chosen evaluative criteria, we have determined that Option #2 (Comprehensive Septic Improvements) has the largest overall impact, is moderately cost effective, and has the potential to be politically feasible. If the Puget Sound Partnership wishes to advocate on behalf of the healthiest Puget Sound possible, comprehensive septic tank improvement is the clear choice. While current political feasibility is moderate to low, our research suggests that with a well-planned education and media campaign to the already sympathetic legislators and citizens of Hood Canal, this option could successfully be implemented. Similarly, alternative and flexible financing options for the purchase of septic tanks could significantly reduce the per-household cost of septic tank improvements. 12 Sources Cited / Consulted Devol, & Newton, J. (2011). Hood Canal Dissolved Oxygen Program - IAM Report. Dunagan, C. (2008, February 29). Bill Calls for New Septic Requirements for Hood Canal. Kitsap Sun. Retrieved May 9, 2011, from http://www.kitsapsun.com/news/2008/feb/29/billcalls-for-new-septic-requirements-for-hood/ Dunagan, C. (2010, October 2). Researchers Pondering Possible Solutions to Hood Canal’s LowOxygen Problem » Kitsap Sun. Kit. Retrieved May 7, 2011, from http://www.kitsapsun.com/news/2010/oct/02/researchers-pondering-possible-solutions-tohood/ Dunagan, C. (2011a, April 12). Study confirms septic tanks contribute to Hood Canal fish kills: Kitsap Sun. Retrieved April 25, 2011, from http://www.kitsapsun.com/news/2011/apr/12/study-confirms-septic-systems-as-primesuspect/?print=1 Dunagan, C. (2011b, April 11). Oxygen Levels Drop Again in Hood Canal» Kitsap Sun. Retrieved April 25, 2011, from http://www.kitsapsun.com/news/2010/sep/28/oxygen-levelsdrop-again-hood-canal/ Dunagan, C. (2011c, May 22). Sewer Upgrades for Hood Canal. Kitsap Sun. 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Retrieved May 9, 2011 from http://www.ci.minneapolis.mn.us/stormwater/fee/stormwater_faq.asp Nature Tourism Benefits Washington Communities | Washington Department of Fish & Wildlife. (1997). Retrieved April 26, 2011, from http://wdfw.wa.gov/viewing/tourism/ Newton, J. (n.d.). The Hood Canal Oxygen Problem and Actions. NOAA-NMFS-NWFSC TM44: Environmental History and Features of Puget Sound. (n.d.). Retrieved April 26, 2011 from http://www.nwfsc.noaa.gov/publications/techmemos/tm44/environment.htm Partnership for Puget Sound (2009). Public Involvement and Outreach Summary. Retrieved May 5, 2011 from http://www.psp.wa.gov/downloads/AAAPX/PIOSummary.pdf PRISM - UW (n.d.). Solving the dissolved oxygen puzzle in Hood Canal. Retrieved May 7, 2011, from http://www.prism.washington.edu/story/Hood+Canal Roberts, M., Zalewsky, B., Swanson, T., Sullivan, L., Sinclair, K., & LeMoine, M. (2004). Quality Assurance Project Plan. Deschutes River, Capitol Lake, and Budd Inlet Temperature, Fecal Coliform Bacteria, Dissolved Oxygen, pH, and Fine Sediment Total Maximum Daily Load Study. Washington State Department of Ecology. Environmental Assessment Program. Olympia, Washington. Publication, 103. Science Primer. (n.d.). HCDOP. Retrieved April 25, 2011, from http://www.hoodcanal.washington.edu/aboutHC/scienceprimer.jsp Straughan Environmental Services, Inc. (January 2003). Literature Review: Riparian Buffer Effectiveness. Retrieved April 25, 2011 from http://esm.versar.com/pprp/bibliography/LiteratureReviews/RiparianBufferEffectiveness.pdf 14 Appendix A: Hood Canal (Hull, 2005) Appendix B: Estimated range of nitrogen contributions to Hood Canal (Fegergren et al, 2004) 15