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TABLE OF CONTENTS

Olympic Coast National Marine Sanctuary

Final Management Plan 

and Environmental Assessment

Olympic Coast

National Marine Sanctuary

Final Management Plan and

Environmental Assessment

September 2011

http://olympiccoast.noaa.gov

i

ABOUT THIS DOCUMENT

This document is a combined final management plan for Olympic Coast National 

Marine Sanctuary as well as the environmental assessment, required under the 

National Environmental Policy Act (NEPA). This document also fulfills 

compliance requirements under Section 106 of the National Historic Preservation 

Act.

This plan will serve as the primary management document of OCNMS for 

approximately the next five to ten years.

Comments or questions on this management plan should be directed to:

George Galasso

Management Plan Review Coordinator

Olympic Coast National Marine Sanctuary

115 East Railroad Avenue, Suite 301

Port Angeles, WA 98362-2925

LIST OF PREPARERS

Liam Antrim, Olympic Coast National Marine Sanctuary (OCNMS)

Lauren Bennett, OCNMS

Craig Bowhay, Northwest Indian Fisheries Commission

George Galasso, OCNMS

Molly Holt, NOAA Office of the General Counsel

Hélène Scalliet, Office of National Marine Sanctuaries

Bruce Terrell, Office of National Marine Sanctuaries

Herrera Environmental Consultants, Inc.

Representatives of the Hoh, Quileute and Makah Tribes and Quinault Indian Nation

Members of the OCNMS Advisory Council and associated working groups

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TABLE OF CONTENTS

ACRONYMS................................................................................................................................. xi

EXECUTIVE SUMMARY ...........................................................................................................xv

1 INTRODUCTION ..................................................................................................................1

1.1 Office of National Marine Sanctuaries ..........................................................................1

1.2 Significance of the Sanctuary ........................................................................................2

1.3 OCNMS‟ Collaborative Management Framework........................................................3

1.4 OCNMS Goals and Objectives......................................................................................5

2 TREATY TRUST RESPONSIBILITY ..................................................................................7

2.1 Coastal Treaty Tribes, the Treaty Right to Fish, and the Magnuson-Stevens 

Fishery Conservation Act ..............................................................................................8

2.2 OCNMS and Tribal Trust and Treaty Responsibilities................................................10

2.3 Consultation with Coastal Treaty Tribes .....................................................................11

2.4 Tribal Consultation Procedures....................................................................................11

3 PURPOSE AND NEED FOR REVISING THE MANAGEMENT PLAN AND 

REGULATIONS ..................................................................................................................13

3.1 Purpose.........................................................................................................................13

3.1.1 National Marine Sanctuaries Act.....................................................................13

3.1.2 Olympic Coast National Marine Sanctuary .....................................................14

3.1.3 Management Plan Review ...............................................................................15

3.2 Need .............................................................................................................................15

3.2.1 Outdated Management Plan.............................................................................15

3.2.2 Changes in Ocean Governance ........................................................................15

3.2.3 Data Gaps.........................................................................................................16

3.2.4 New Technologies ...........................................................................................17

3.2.5 Recent and Emerging Issues............................................................................17

4 MANAGEMENT PLAN REVIEW PROCESS ...................................................................19

4.1 Overview of the MPR Process.....................................................................................19

4.1.1 Public Involvement ..........................................................................................20

4.2 MPR Preliminary Priority Topics................................................................................21

4.3 Summary of Public Scoping ........................................................................................22

4.4 Issue Prioritization and Final Priority Topics..............................................................24

4.5 Working Groups and Workshops.................................................................................25

4.6 Action Plans.................................................................................................................26

4.7 Improving Collaboration through the MPR process....................................................27

4.8 Scoping Ideas Considered but Not Developed as Alternatives ...................................28

4.8.1 Boundary Expansion........................................................................................28

4.8.2 Alternative Energy Development ....................................................................28
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4.8.3 Compatibility Determinations..........................................................................28

4.8.4 No-take Zones/Marine Reserves......................................................................28

4.8.5 Aquaculture Ban ..............................................................................................29

4.8.6 Harbors of Refuge............................................................................................29

5 FINAL MANAGEMENT PLAN .........................................................................................31

5.1 Introduction..................................................................................................................31

5.2 Action Plans.................................................................................................................32

A. Achieve Effective Collaborative and Coordinated Management ....................33

A1. Collaborative and Coordinated Sanctuary Management Action 

Plan.....................................................................................................34

A2. Community Involvement in Sanctuary Management Action 

Plan.....................................................................................................39

A3. Sanctuary Operations Action Plan .....................................................42

B. Conduct Collaborative Research, Assessments and Monitoring to 

Inform Ecosystem-Based Management ...........................................................47

B1. Habitat Mapping and Classification Action Plan ...............................49

B2. Physical and Chemical Oceanography Action Plan ...........................52

B3. Populations, Communities and Ecosystems Action Plan...................55

B4. Data Management, Sharing and Reporting Action Plan ....................60

C. Improve Ocean Literacy ..................................................................................62

C1. K-12 Education Action Plan...............................................................64

C2. Higher Education Action Plan............................................................67

C3. Visitor Services Action Plan ..............................................................69

C4. Community Outreach Action Plan .....................................................71

D. Conserve Natural Resources in the Sanctuary.................................................73

D1. Spills Prevention, Preparedness, Response and Restoration 

Action Plan.........................................................................................74

D2. Climate Change Action Plan ..............................................................80

D3. Marine Debris Action Plan.................................................................83

D4. Wildlife Disturbance Action Plan ......................................................85

D5. Water Quality Protection Action Plan................................................88

D6. Habitat Protection Action Plan...........................................................90

D7. Regional Ocean Planning Action Plan ...............................................92

E. Understand the Sanctuary‟s Cultural, Historical and Socioeconomic 

Significance......................................................................................................94

E1. Maritime Heritage Action Plan ..........................................................95

E2. Socioeconomic Values of Resources in the Sanctuary Action 

Plan.....................................................................................................98

5.3 Performance Measures...............................................................................................100

5.4 Cost Estimates and Timelines....................................................................................103

5.5 Implementation Table ................................................................................................106

5.5.1 Explanation of Implementation Table ...........................................................106

6 AFFECTED ENVIRONMENT..........................................................................................113

6.1 Physical Setting..........................................................................................................113
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6.1.1 Geography and Geology ................................................................................115

6.1.2 Oceanography ................................................................................................115

6.1.3 Water Quality.................................................................................................117

6.1.3.1 Vessel Discharges.............................................................................117

6.1.4 Climate/Meteorology .....................................................................................129

6.1.5 Climate Change..............................................................................................129

6.2 Biological Setting.......................................................................................................130

6.2.1 Intertidal Habitats...........................................................................................130

6.2.2 Nearshore Habitats.........................................................................................131

6.2.3 Pelagic (Water Column) Habitats..................................................................132

6.2.4 Seafloor Habitats............................................................................................133

6.2.5 Benthic Invertebrates.....................................................................................136

6.2.6 Fishes .............................................................................................................136

6.2.7 Seabirds..........................................................................................................137

6.2.8 Marine Mammals...........................................................................................138

6.3 Cultural and Historical Setting...................................................................................140

6.3.1 American Indian Cultural Resources.............................................................140

6.3.2 Historical and Archaeological Resources......................................................141

6.3.2.1 Historical Contexts...........................................................................141

6.3.2.2 Archaeological Resources................................................................142

6.3.2.3 Maritime Cultural Landscape ...........................................................143

6.4 Human/Socioeconomic Setting..................................................................................145

6.4.1 Population, Housing, Income, and Employment ...........................................145

6.4.2 Maritime Transportation ................................................................................149

6.4.3 Commercial Fishing.......................................................................................152

6.4.4 Developed Environment ................................................................................153

6.4.5 Department of Defense Activities..................................................................155

6.4.6 U.S. Coast Guard/Homeland Security Activities...........................................157

6.4.7 Recreational Fishing ......................................................................................158

6.4.8 Recreation and Tourism.................................................................................158

6.4.9 Research and Monitoring...............................................................................159

6.4.10 Education and Outreach.................................................................................160

6.4.11 Passive Users .................................................................................................160

7 DESCRIPTION OF ALTERNATIVES .............................................................................163

7.1 Alternative A (no-action alternative).........................................................................164

7.2 Alternative B (preferred alternative)..........................................................................165

7.3 Alternative C (not preferred) .....................................................................................166

8 ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES ....................................173

8.1 Physical Setting..........................................................................................................178

8.1.1 Actions with Negligible Effects to the Physical Setting................................178

8.1.2 Actions with Beneficial Effects to the Physical Setting ................................181

8.1.2.1 Routine Activities – Effects to the Physical Setting.........................181
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8.1.2.2 Cruise Ship Wastewater Discharges – Effects to the Physical 

Setting...............................................................................................182

8.1.2.3 Wastewater Discharges from Vessels over 300 Gross Tons –

Effects to the Physical Setting..........................................................185

8.1.2.4 Area-to-be-Avoided – Effects to the Physical Setting .....................185

8.1.2.5 Invasive Species Discharge Regulation – Effects to the 

Physical Setting ................................................................................191

8.1.3 Actions with Adverse Effects to the Physical Setting ...................................192

8.1.3.1 Overflight Floor Reduction – Effects to the Physical Setting ..........192

8.1.3.2 Seabed Disturbance from Research Activities – Effects to the 

Physical Setting ................................................................................192

8.1.3.3 Operating Vessels in Sanctuary – Effects to the Physical 

Setting...............................................................................................193

8.1.3.4 Conducting Activities in Intertidal Areas – Effects to the 

Physical Setting ................................................................................195

8.1.4 Summary of Effects to Physical Setting ........................................................196

8.2 Biological Setting.......................................................................................................197

8.2.1 Actions with Negligible Effect to Biological Setting ....................................197

8.2.2 Actions with Beneficial Effects to the Biological Setting .............................199

8.2.2.1 Routine Activities – Effects to the Biological Setting .....................199

8.2.2.2 Vessel Discharges – Effects to the Biological Setting .....................200

8.2.2.3 Area-to-be-Avoided – Effects to the Biological Setting ..................202

8.2.2.4 Invasive Species Discharge Regulation – Effects to the 

Biological Setting .............................................................................203

8.2.3 Actions with Adverse Effects to the Biological Setting ................................203

8.2.3.1 Conducting Wildlife Research, Assessments and Monitoring –

Effects to the Biological Setting.......................................................204

8.2.3.2 Operating Hydrographic Sonar in the Sanctuary – Effects to 

the Biological Setting .......................................................................204

8.2.3.3 Seabed Disturbance from Research Activities – Effects to the 

Biological Setting.............................................................................206

8.2.3.4 Operating Vessels in Sanctuary – Effects to the Biological 

Setting...............................................................................................207

8.2.3.5 Conducting Activities in Intertidal Areas – Effects to the 

Biological Setting .............................................................................208

8.2.4 Summary of Effects to Biological Resources................................................209

8.3 Historical/Cultural Setting .........................................................................................210

8.3.1 Actions with Negligible Effect to the Historical/Cultural Setting .................210

8.3.2 Actions with Beneficial Effects to the Historical/Cultural Setting................212

8.3.2.1 Routine Education, Outreach, Visitor Services, Resource 

Protection and Administrative Program Activities – Effects to 

the Historical/Cultural Setting..........................................................212

8.3.2.2 Operating Sonar for Hydrographic Surveying – Effects to the 

Historical/Cultural Setting................................................................213

8.3.2.3 Routine Maritime Heritage Activities – Effects to the 

Historical/Cultural Setting................................................................213
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8.3.3 Actions with Adverse Effects to the Historical/Cultural Setting...................214

8.3.3.1 Compliance with Section 106 of the NHPA – Effects to the 

Historical/Cultural Setting................................................................214

8.3.4 Summary of Effects to Historical/Cultural Setting........................................215

8.4 Human/Socioeconomic Setting..................................................................................216

8.4.1 Actions with Negligible Effects to the Human/Socioeconomic Setting........216

8.4.2 Actions with Beneficial Effects to the Human/Socioeconomic Setting ........218

8.4.2.1 Routine Activities.............................................................................218

8.4.2.2 Cruise Ship Discharges – Effects to the 

Human/Socioeconomic Setting ........................................................220

8.4.3 Actions with Adverse Effects to the Human/Socioeconomic Setting ...........222

8.4.3.1 Regulatory Reduction in Overflight Floor (alternative C only) 

– Effects to the Human/Socioeconomic Setting...............................223

8.4.3.2 Changes to Vessel Discharge Regulation (alternative C) –

Effects to the Human/Socioeconomic Setting..................................223

8.4.3.3 Area-to-be-Avoided – Effects to the Human/Socioeconomic 

Setting...............................................................................................225

8.4.3.4 Regulatory Ban on Invasive Species Discharge – Effects to 

the Human/Socioeconomic Setting ..................................................226

8.4.4 Summary of Effects to Human/Socioeconomic Setting ................................226

8.5 Cumulative Effects.....................................................................................................228

8.5.1 Cumulative Effects of Seafloor Disturbance .................................................229

8.5.2 Cumulative Effects of Noise Pollution ..........................................................229

8.5.3 Cumulative Effects of Vessel Operations......................................................230

8.5.4 Cumulative Effects of Trampling ..................................................................230

8.5.5 Cumulative Effects of Invasive Species Regulations ....................................230

8.5.6 Cumulative Effects of Vessel Discharges......................................................230

8.5.7 Cumulative Effects of Climate Change .........................................................231

8.5.8 Cumulative Effects of Marine Resource Protection ......................................231

8.5.9 Actions for Future Analysis...........................................................................232

8.6 Summary of Effects ...................................................................................................233

9 PERSONS AND AGENCIES CONTACTED ...................................................................235

10 REFERENCES ...................................................................................................................239

APPENDIX A – TERMS OF DESIGNATION ..........................................................................247

APPENDIX B – NOTICE OF INTENT FOR INITIATION OF MANAGEMENT PLAN 

REVIEW.............................................................................................................................253

APPENDIX C – INITIATION OF SECTION 106 CONSULTATION .....................................257

APPENDIX D – ENHANCING THE INTERGOVERNMENTAL PARTNERSHIP (EO 

12875).................................................................................................................................261

APPENDIX E – EXECUTIVE ORDER 12898 ..........................................................................265
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APPENDIX F – SECRETARIAL ORDER 3206........................................................................273

APPENDIX G – EXECUTIVE ORDER 13084..........................................................................283

APPENDIX H – PRESIDENTIAL MEMORANDUM OF NOVEMBER 5, 2009....................289

APPENDIX I – EXECUTIVE ORDER 13175 ...........................................................................293

APPENDIX J – DEPARTMENT OF COMMERCE AMERICAN INDIAN AND 

ALASKA NATIVE POLICY.............................................................................................299

APPENDIX K – DISCHARGE ESTIMATION METHODOLOGY .........................................305

APPENDIX L – RESPONSES TO COMMENTS ......................................................................313
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FIGURES

Figure 1 National Marine Sanctuary System ...............................................................................1

Figure 2 Diagram showing jurisdictional boundaries within OCNMS......................................35

Figure 3 Olympic Coast National Marine Sanctuary ...............................................................114

Figure 4 Schematic of general physical factors controlling ocean surface response 

during January, May, July, and September (from Pirhalla et al. 2009).....................116

Figure 5 Kelp distribution ........................................................................................................132

Figure 6 Habitat map................................................................................................................134

Figure 7 Potential historic distribution of biologically structured habitat associated with 

hard substrate overlaid on Olympic 2 EFH Conservation Area (data from Curt 

Whitmire, NOAA) .....................................................................................................135

Figure 8 Vessel traffic management system.............................................................................151

Figure 9 Location of the Alaska United and Pacific Crossing fiber optic cables ....................154

Figure 10 Military Operating Areas...........................................................................................156

Figure 11 CVTS radar coverage – OCNMS 2009 transit track lines (6,128 transits)................189

Figure 12 CVTS radar coverage – ATBA 2009 transit track lines (68 transits)........................190

Figure 13 OCNMS Research Vessel Tatoosh ............................................................................194

Figure 14 OCNMS mooring anchor...........................................................................................207

Figure 15 Extent of the Canadian Coast Guard radar coverage within OCNMS.......................308

Figure 16 WDFW Marine Areas and OCNMS Boundary .........................................................310
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TABLE OF CONTENTS

TABLES

Table 1 Olympic Coast National Marine Sanctuary Goals and Objectives................................5

Table 2 List of 37 topics raised during scoping........................................................................23

Table 3 Olympic Coast National Marine Sanctuary Final Management Plan Action 

Plans.............................................................................................................................31

Table 4 Cost estimates associated with the action plan strategies (in thousands of 

dollars). ......................................................................................................................103

Table 5 OCNMS Management Plan Implementation Table...................................................107

Table 6 Potential gallons of sewage discharges in OCNMS in 2009 .....................................120

Table 7 Potential gallons of graywater discharges in OCNMS in 2009 .................................123

Table 8 Population, housing and income for counties adjacent to OCNMS ..........................145

Table 9 Population, housing and income for American Indian Tribes adjacent to 

OCNMS .....................................................................................................................146

Table 10 Employment in counties adjacent to OCNMS (2008)...............................................148

Table 11 All Cooperative Vessel Traffic Service (CVTS) vessel transits in 2009. For 

transits in OCNMS, the cumulative time and average transit time in OCNMS 

for all vessels of a given classification combined is provided for each vessel 

class............................................................................................................................150

Table 12 Summary of three alternatives analyzed ....................................................................163

Table 13 Summary of analyzed actions....................................................................................174

Table 14 Comparison of estimated potential discharges (in gallons) under alternatives 

A, B and C..................................................................................................................186

Table 15 All Cooperative Vessel Traffic Service (CVTS) vessel transits in 2009...................188

Table 16 Echosounder specifications for equipment most commonly used by OCNMS 

for hydrographic surveys ...........................................................................................205

Table 17 Regulatory framework governing graywater and (sewage) blackwater 

discharges from vessels over 300 GT into OCNMS..................................................221

Table 18 Comparison of effects of the three alternatives on physical, biological, 

historic/cultural and socioeconomic resources ..........................................................233

Table 19 Comparison of vessel data sources............................................................................307

Table 20 Recreational fishing boat trips, within OCNMS, for 2009 ........................................309

Table 21 Recreational fishing angler trips, within OCNMS, for 2009 .....................................311
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ACRONYMS

ACRONYMS

AC Olympic Coast National Marine Sanctuary Advisory Council

ADEC Alaska Department of Environmental Conservation

ADV Annual Discharge Volume

AIS Automated Identification System

AOP Annual Operating Plan

AOPA Aircraft Owners and Pilots Association

ATBA Area-to-be-Avoided

AUV Autonomous Underwater Vehicle

AWTS Advanced Wastewater Treatment System

CMECS Coastal and Marine Ecological Classification Standard

CMSP Coastal and Marine Spatial Planning

COASST Coastal Observation and Seabird Survey Team

CSS Carbon Saturation State

CVTS Cooperative Vessel Traffic Service

CWA Clean Water Act

DEA Draft Environmental Assessment

DFO Department of Fisheries and Ocean (Canada)

DMP Draft Management Plan

DO Dissolved Oxygen

DOC Department of Commerce

DOD Department of Defense

DOI Department of Interior

EA Environmental Assessment

EBM Ecosystem Based Management

EFH Essential Fish Habitat

ENSO El Nino/La Nina Southern Oscillation

EPA Environmental Protection Agency

ESA Endangered Species Act

FAA Federal Aviation Administration

FGDC Federal Geographic Data Committee

FMP Final Management Plan

FOSC Federal On-Scene Coordinator

GIS Geographic Information System

GRP Geographic Response Plans

GT Gross Tons

HAB Harmful Algal Blooms

HAPC Habitat Areas of Particular Concern

ICS Incident Command System

IMO International Maritime Organization

IPC Olympic Coast Intergovernmental Policy Council 

IT Information Technology

MARINe Multi-Agency Rocky Intertidal Network

MCTS Marine Communications and Traffic Services
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ACRONYMS

MMS Minerals Management Service

MMPA Marine Mammal Protection Act

MOA Memorandum of Agreement

MOU Memorandum of Understanding

MPR Management Plan Review

MRC Marine Resource Committees

MSD Marine Sanitation Device

NANOOS Northwest Association of Networked Ocean Observing Systems

NBDC National Buoy Data Center

NCDC National Climatic Data Center

NCDDC NOAA Coastal Data Development Center

NDZ No Discharge Zone

NEPA National Environmental Policy Act

NGO Non-governmental organization

NHPA National Historic Preservation Act

NMFS National Marine Fisheries Service

NMSA National Marine Sanctuaries Act

NOAA National Oceanic and Atmospheric Administration

NOS National Ocean Service

NPS National Park Service

NRDA Natural Resource Damage Assessment 

NWAC Northwestern Area Committee

NWACP Northwestern Area Contingency Plan

NWCCA North West & Canada Cruise Association

NWFSC NOAA Northwest Fisheries Science Center

NWSC Northwest Straits Commission

NWTRC Northwest Training Range Complex

OAP Washington Ocean Action Plan

OCNMS Olympic Coast National Marine Sanctuary

OLE National Marine Fisheries Service Office of Law Enforcement

ONMS Office of National Marine Sanctuaries

ONMS WCRO Office of National Marine Sanctuaries West Coast Regional Office

ONP Olympic National Park

ORHAB Olympic Region Harmful Algal Bloom Partnership 

ORR NOAA Office of Response and Restoration

OSLTF Oil Spill Liability Trust Fund

OSU Oregon State University

PAC Procurement, Acquisition, Construction 

PaCOOS Pacific Coast Ocean Observing System

PFMC Pacific Fisheries Management Council

PISCO Partnership for Interdisciplinary Studies of Coastal Oceans

PMEL NOAA Pacific Marine Environmental Laboratory

QUTR Quinault Underwater Tracking Range

REEF Reef Environmental Education Foundation

ROP Regional Ocean Planning

ROV Remotely Operated Vehicle
xiii

ACRONYMS

RRT Regional Response Team

SECO NOAA Safety and Environmental Compliance Office

SHIELDS Sanctuary Hazardous Incident Emergency Logistics Database System

SHPO State Historic Preservation Office

SIMoN Sanctuary Integrated Monitoring Network

SOC Standards of Care

THPO Tribal Historic Preservation Office

TNC The Nature Conservancy

USACE U.S. Army Corps of Engineers

USCG U.S. Coast Guard

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

UV Ultraviolet Light

UW/APL University of Washington Applied Physics Lab

VEAT Vessel Entry and Transit

VGP Vessel General Permit

VMS Vessel Monitoring System

VTSPS Vessel Traffic Service Puget Sound

WCCA Washington Clean Coast Alliance

WCGA West Coast Governors‟ Agreement

WDFW Washington Department of Fish and Wildlife

WDNR Washington Department of Natural Resources

WDE Washington Department of Ecology

WPA Washington Pilots Association

WSDOT Washington Department of Transportation

WSPRC Washington State Parks and Recreation Commission

WWU Western Washington University

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EXECUTIVE SUMMARY

EXECUTIVE SUMMARY

Designated in 1994, Olympic Coast National Marine Sanctuary (OCNMS or sanctuary) is a place 

of regional, national and global significance. The sanctuary, which is connected to both the Big 

Eddy Ecosystem and the California Current Large Marine Ecosystem, is the site of one of North 

America‟s most productive marine regions and spectacular, undeveloped shorelines.

OCNMS‟ current management plan was written at the time of sanctuary designation in 1994. A 

sanctuary management plan is a site-specific planning and management tool that describes the 

goals, objectives and activities for a sanctuary, and guides future activities. NOAA‟s Office of

National Marine Sanctuaries (ONMS) is required by the National Marine Sanctuaries Act

(NMSA) to review and revise, if necessary, sanctuary management plans at periodic intervals. 

The 1994 management plan was written to give broad, general direction for the formation of 

OCNMS‟ program areas. Many of the activities it describes are too general to provide useful 

guidance now that OCNMS is over a decade old. Sixteen years after sanctuary designation, 

OCNMS is in need of more refined and directed guidance. 

Since fall 2008, ONMS has worked closely with the OCNMS Advisory Council (AC), the 

Olympic Coast Intergovernmental Policy Council (IPC) and the public to review and revise the 

1994 management plan. Commonly referred to as management plan review or MPR, for 

OCNMS this process was also labeled “Navigating the Future.” OCNMS‟ MPR process has 

focused and will continue to focus on public and stakeholder involvement and to ensure all 

aspects of MPR are transparent. ONMS went through a detailed issue analysis process with the 

AC and the IPC, which included a series of AC working group meetings and workshops to 

explore priority issues in greater detail. These AC working groups and workshops involved over 

100 subject area experts and interested members of the public. Through these meetings, specific 

strategies and activities for the revised management plan were developed. The AC then 

reviewed these suggested strategies and activities, recommended minor changes and voted to 

forward them to the OCNMS Superintendent with a recommendation they be included in the 

revised management plan.

This document includes both the final management plan (FMP) and an environmental assessment 

(EA) that analyzes the impacts of the FMP. The EA fulfills compliance requirements under the 

National Environmental Policy Act (NEPA) and Section 106 of the National Historic 

Preservation Act (NHPA) in accordance with 36 CFR 800.8(c).

Section 1 (Introduction) of the document introduces OCNMS, the Office of National Marine 

Sanctuaries (ONMS) and the National Marine Sanctuaries Act (NMSA). This section also 

presents the revised goals and objectives for OCNMS, which were developed as part of the MPR 

process and are considered an integral part of the FMP. 

Section 2 (Treaty Trust Responsibility) focuses on explaining the nature and significance of

OCNMS‟ treaty trust responsibility to the Hoh, Quileute and Makah Tribes and Quinault Indian 

Nation. A team of sanctuary, tribal and Northwest Indian Fisheries Commission representatives 

wrote this section jointly. OCNMS‟ treaty trust responsibility is an integral part of its mission;
xvi

EXECUTIVE SUMMARY

and fulfilling this responsibility is critical to the successful implementation of this management 

plan. This section provides critical supporting information for both the FMP and the EA. 

Section 3 (Purpose and Need) summarizes the purpose of and need for reviewing and revising 

the OCNMS management plan. This section is required by NEPA implementing regulations.

The purpose and need section also provides important context and support for the FMP. 

Section 4 (MPR Process) summarizes the history of the MPR process to facilitate transparency 

by explaining systematically the process by which the FMP was developed. Included in this 

section is a discussion of topics raised during the public MPR scoping process but not developed 

as management plan alternatives. 

Section 5 is the FMP, which consists of 20 action plans grouped under five priority needs. 

During the MPR process, six priority needs were identified. In recognition of its unique nature 

and importance the priority need to fulfill treaty trust responsibility was developed into section 2 

of this document. The remaining five priority needs are addressed by the action plans. The

action plans are comprised of a series of non-regulatory actions, regulatory strategies, and 

activities. The management plan includes a total of 84 strategies and 293 activities. Each action 

plan also includes a desired outcome, links to the revised OCNMS goals, and a list of key 

partners. 

Included at the end of the FMP are a set of performance measures, cost estimates for each 

strategy, and an implementation table prioritizing strategies. It is estimated it would take an 

annual budget of $4.2 to $5.4 million to implement all of the strategies in the FMP effectively 

over the next five years (Table 4). OCNMS currently operates with an annual budget of around 

$1.5 million, not including in-kind support from other NOAA offices or grants from NOAA or 

other agencies and organizations. The amount of in-kind support and grant funding OCNMS 

receives each year varies greatly. Thus, in order to implement the entire FMP, ONMS would 

need to significantly increase directed funding for OCNMS management (whether through 

project-specific allocation or base funding). Given the substantial federal budget constraints 

anticipated for the next few years, OCNMS staff worked with its AC and the IPC to develop the 

implementation table that appears at the end of the FMP. The implementation table explains 

what strategies will be the highest priorities for ONMS to implement under three potential 

budget scenarios: level-funding (i.e., no budget increase), a moderate budget increase and a 

significant budget increase. ONMS will use the implementation table to guide and inform its 

annual operating planning efforts. 

The FMP, while it can be considered a stand-alone document, is also an important component of 

the EA. The role of the EA is to analyze the action of revising the OCNMS management plan. 

The FMP presented in section 5 is ONMS‟s preferred management plan revision. Later sections 

of the document related specifically to the EA analyze the environmental consequences of the 

FMP as well as other alternatives for revising the management plan. 
xvii

EXECUTIVE SUMMARY

OCNMS Final Management Plan - Action Plans

A. Achieve Effective Collaborative and Coordinated Management

A1. Collaborative and Coordinated Sanctuary Management Action Plan

A2. Community Involvement in Sanctuary Management Action Plan

A3. Sanctuary Operations Action Plan

B. Conduct Collaborative Research, Assessments and Monitoring to Inform Ecosystem-Based 

Management

B1. Habitat Mapping and Classification Action Plan

B2. Physical and Chemical Oceanography Action Plan

B3. Populations, Communities and Ecosystems Action Plan

B4. Data Management, Sharing and Reporting Action Plan

C. Improve Ocean Literacy

C1. K-12 Education Action Plan

C2. Higher Education Action Plan

C3. Visitor Services Action Plan

C4. Community Outreach Action Plan

D. Conserve Natural Resources in the Sanctuary

D1. Spills Prevention, Preparedness, Response and Restoration Action Plan

D2. Climate Change Action Plan

D3. Marine Debris Action Plan

D4. Wildlife Disturbance Action Plan

D5. Water Quality Protection Action Plan

D6. Habitat Protection Action Plan

D7. Regional Ocean Planning Action Plan

E. Understand the Sanctuary’s Cultural, Historical and Socioeconomic Significance

E1. Maritime Heritage Action Plan

E2. Socioeconomic Values of Resources in the Sanctuary Action Plan
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EXECUTIVE SUMMARY

Section 6 (Affected Environment) provides a detailed description of the environment (biological, 

physical and human) affected by the action of revising the OCNMS management plan. The 

action plans in the FMP are purposefully written in a concise manner and do not provide 

extensive background information. The background and supporting information for the action 

plans is in the affected environment discussion. 

Section 7 (Description of Alternatives) summarizes three alternatives (A, B and C) considered 

for revising the management plan. One of these alternatives (alternative B, the preferred

alternative) is the FMP presented in section 5. In accordance with NOAA NEPA guidelines, 

ONMS also considered two other alternatives: alternative A – a “no-action” alternative (in which 

the 1994 management plan would not be revised at all), and alternative C (in which the 1994 

management plan would be revised but in way different from the preferred alternative). 

Section 8 (Environmental Consequences of Alternatives) provides a detailed analysis of the 

potential effects of all three alternatives on the biological, physical, and human resources 

discussed in the affected environment (section 6). Section 8 fulfills ONMS‟ responsibility under 

NEPA to analyze the potential beneficial and adverse effects of its actions on the environment. 

Additionally, Section 106 of the NHPA requires federal agencies to analyze the potential impacts 

of their actions on historic properties and resources (as defined under the NHPA). This analysis 

is also incorporated into section 8 of the document. 

The findings of the Environmental Consequences section indicate revision of the OCNMS 

management plan under all three alternatives would have a less than significant effect on the 

biological, physical, and human environment, both as an individual action and cumulatively with 

other actions. 

It should also be noted that NOAA is concurrently issuing a final rule in the Federal Register to 

make changes to OCNMS regulations under the preferred alternative. Descriptions of these 

regulatory changes appear in the FMP (section 5); and the environmental consequences of these 

regulatory changes are analyzed in section 8. 

Sections 9 and 10 list the persons and agencies contacted during the management plan review 

process and the references cited in this document, respectively. 

Finally, the appendices include supporting document such as the OCNMS Designation 

Document, the Proposed Rule announcing initiation of management plan and regulations review, 

relevant Executive and Secretarial orders, and the Response to Comments, including comments 

on all components of the management plan, environmental assessment, and regulations.
1

INTRODUCTION

1 INTRODUCTION

1.1 OFFICE OF NATIONAL MARINE SANCTUARIES

The Office of National Marine Sanctuaries (ONMS) serves as a trustee for a system of 14 marine 

protected areas (13 national marine sanctuaries and Papahanāumokuākea Marine National 

Monument, Figure 1), which together encompass more than 290,000 square miles of marine and 

Great Lakes waters from Washington state to the Florida Keys, and from New England to 

American Samoa. 

Figure 1 National Marine Sanctuary System

The ONMS is an office within the National Ocean Service of the National Oceanic and 

Atmospheric Administration (NOAA). The ONMS works cooperatively with other 

governments, agencies, resource users and the public to protect the living, non-living, and 

cultural marine resources of sanctuaries while allowing recreational and commercial activities 

that are compatible with the NMSA‟s primary goal of resource protection. The ONMS also 

raises public awareness and deepens understanding of sanctuary resources and management 

issues through research, monitoring, exploration, education and outreach programs.

Throughout its work ONMS is guided by these vision and mission statements (ONMS 2005): 

Vision - The National Marine Sanctuary Program is a world-class system of sanctuaries 

that protect the nation’s natural and cultural marine resources for this and future 

generations and provides both national and international leadership for marine 

conservation.
2

INTRODUCTION

Mission - Identify, protect, conserve, and enhance the natural and cultural resources, 

values, and qualities of the National Marine Sanctuary System for this and future 

generations throughout the nation.

National marine sanctuaries are an essential part of the country‟s collective environmental riches. 

Within their protected waters, giant whales feed, breed and nurse their young, coral colonies 

flourish, and shipwrecks tell stories of our maritime history. Sanctuary habitats include beautiful 

reefs, lush kelp forests, whale migration corridors and destinations, spectacular deep-sea 

canyons, and underwater archeological sites. The areas range in size from one-quarter 

square mile (American Samoa‟s Fagatele Bay) to the more than 140,000 square miles 

(Papahanāumokuākea Marine National Monument in the Northwestern Hawaiian Islands). 

Each sanctuary is a unique place requiring special protections. Serving as natural classrooms, 

cherished recreation spots, places for valuable commercial activities, and places of profound

cultural significance, national marine sanctuaries represent many things to many people. 

1.2 SIGNIFICANCE OF THE SANCTUARY

Designated by NOAA in 1994 (Appendix A), Olympic Coast National Marine Sanctuary 

(OCNMS or the sanctuary) is a place of regional, national and global significance. OCNMS, 

which is connected to both the Big Eddy Ecosystem and the California Current Large Marine 

Ecosystem, is home to one of North America‟s most productive marine regions and spectacular,

undeveloped shorelines.

Article III of the OCNMS terms of designation identifies “characteristics of the sanctuary area 

that give it particular value” (59 FR 24586, May 11, 1994; Appendix A). These characteristics 

include a highly productive ocean and coastal environment that is important to the continued 

survival of numerous ecologically and commercially important species of fish, seabirds, and 

marine mammals; a diversity of habitats supporting a great variety of biological communities; 

significant historical resources; and exceptional opportunities for scientific research and public 

education and awareness programs. Additional description of the environment in the area of the 

sanctuary is provided in section 6 and in the 2008 OCNMS Condition Report (ONMS 2008). 

OCNMS spans 2,408 square nautical miles (8,259 square kilometers) of marine waters 

off Washington state‟s rugged Olympic Peninsula coast. Extending seaward 40 to 72 kilometers 

(25 to 45 miles) and to depths of over 1,400 meters (4,500 feet), the sanctuary covers much 

of the continental shelf and the heads of three major submarine canyons. Approximately 17% 

of the sanctuary is located within state of Washington waters. OCNMS covers an area is 

approximately 1.7 times larger than the entire Puget Sound and is almost 2.5 times larger than 

Olympic National Park.

The sanctuary borders one of the few undeveloped coastlines remaining in North America, 

enhancing the protection provided by both Olympic National Park, which includes 52 miles

(87 kilometers) of wilderness shoreline adjacent to the sanctuary and the Washington Maritime 

National Wildlife Refuge Complex, which includes more than 600 offshore islands and emergent 

rocks within the sanctuary. Olympic National Park is designated a World Heritage Site and a 

UNESCO Biosphere Reserve. 
3

INTRODUCTION

Located in a nutrient-rich upwelling zone, the sanctuary supports high primary productivity and 

is home to a diversity of organisms and habitats. Twenty-nine species of marine mammals have 

been sighted in the sanctuary, and the seabird colonies off the Olympic Coast are among the largest 

in the continental United States. Commercially important fish species in the sanctuary include 

groundfish, shellfish and five species of salmon. Influenced by geology, ocean currents and other 

global processes, OCNMS‟ temperate location and physical environment support critical habitats 

and unique communities of organisms, including deep sea corals and one of the most diverse 

seaweed communities in the world.

Beyond its ecological significance, the sanctuary has extraordinary cultural significance. For 

time immemorial, American Indians have inhabited and cared for the coastal and marine 

ecosystems that are now part of the sanctuary. The Hoh, Makah and Quileute tribes, and the 

Quinault Indian Nation, collectively referred to in this document as “the Coastal Treaty Tribes”,

continue to make their home on the Olympic Peninsula‟s outer coast maintaining the continuity 

of cultures that remain intimately connected with the ocean and its resources. 

The sanctuary also hosts commercial enterprises, local and international. Some of the busiest 

shipping lanes in the world run through sanctuary. Commercial fisheries, both tribal and nontribal, occur in sanctuary waters and are critical components of the regional economy.

1.3 OCNMS’ COLLABORATIVE MANAGEMENT FRAMEWORK

In managing OCNMS, ONMS is guided by the following mission statement:

Mission - to protect the Olympic Coast’s natural and cultural resources through 

responsible stewardship, to conduct and apply research to preserve the area’s ecological 

integrity and maritime heritage, and to promote understanding through public outreach 

and education.

OCNMS is managed using a collaborative management framework unique to the sanctuary 

system and the world. Given the sanctuary is adjacent to Canada and is encompassed by the 

usual and accustomed areas of the Hoh, Makah, and Quileute tribes, and the Quinault Indian 

Nation, OCNMS‟ management framework is truly multi-national and multi-cultural in nature. 

The Coastal Treaty Tribes have treaty-protected fishing rights and share co-management 

responsibilities for fishing activities within the sanctuary with the state of Washington and 

federal government. These common interests and joint authorities led the Coastal Treaty Tribes, 

the state of Washington and ONMS to create the Olympic Coast Intergovernmental Policy 

Council (IPC) in 2007. The first of its kind in the nation, the IPC provides a regional forum for 

resource managers to exchange information, coordinate policies, and develop recommendations 

for resource management within the sanctuary. 

The IPC‟s goals include:

 Protecting the safety and health of coastal residents;

 Enhancing the social and economic vitality of coastal communities; and

 Improving the understanding and management of marine resources.
4

INTRODUCTION

List of Advisory Council (AC) seats 

and their voting status (2010)

Makah Tribe Voting

Quileute Tribe Voting

Hoh Tribe Voting

Quinault Indian Nation Voting

Citizen-at-large Voting

Education Voting

Research Voting

Conservation/Environmental Voting

Chamber of Commerce, 

Tourism, Recreation

Voting

Marine Business/Ports/

Industry

Voting

Commercial Fishing Voting

Washington Department of 

Ecology

Voting

Washington Department of 

Natural Resources

Voting

Washington Department of 

Fish and Wildlife

Voting

Local Counties (rotating seat) Voting

Northwest Straits Commission Non-voting

U.S. Department of Homeland 

Security/ U.S. Coast Guard

Non-voting

Olympic National Park Non-voting

Washington Maritime National 

Wildlife Refuge Complex

Non-voting

NOAA National Marine 

Fisheries Service

Non-voting

U.S. Navy Non-voting

Since its inception, the IPC has laid the groundwork for successful government-to-government 

collaboration, focusing on the following activities: 

 Participating in the review of OCNMS‟ management plan;

 Identifying research priorities, including the development of a five-year Ocean 

Ecosystem Monitoring and Research Initiative;

 Establishing initial priorities for a transition to ecosystem-based management;

 Seeking stable and long-term funding to support operation of the IPC; and

 Collaborating on planning for a 

national symposium focused on 

climate change and indigenous 

coastal cultures.

Sanctuary management also relies on 

community and stakeholder involvement. 

In addition to working with the IPC, 

ONMS works closely with the OCNMS 

21-seat Advisory Council (AC). The AC, 

established in 1996, consists of 

representatives from four Coastal Treaty 

Tribes, nine state and federal agencies, 

local governments, and a variety of local 

user and interest groups who provide 

advice to the Sanctuary Superintendent. 

All AC meetings are open to the public 

with agendas providing opportunity for 

public comment. 

The AC provides advice to the OCNMS

Superintendent on the management and 

protection of the sanctuary, and deliberates 

and provides recommendations on 

sanctuary operations, education and 

outreach programs, research and science

programs, regulations and enforcement

efforts, and marine policy and management 

plans. The AC also provides advice to 

ONMS on national and regional issues 

impacting the OCNMS such as ocean 

acidification. The AC has played a vital 

role in decisions affecting Olympic Coast 

marine resources. To date, the AC has 

focused on issues such as oil spill 

preparedness and prevention, vessel traffic 

measures, fiber optic cables, alternative 

energy and military activities within the 
5

INTRODUCTION

sanctuary. The AC has also helped define research and educational programmatic priorities. 

Both the AC and the IPC have been invaluable in guiding the MPR process.

Not only is OCNMS management based on a collaborative, community-based framework, 

but OCNMS managers also participate on a larger regional and national stage acting as key 

players in a variety of statewide, regional and international collaborative ocean management 

frameworks. The West Coast Governor‟s Agreement on Ocean Health, the Washington Ocean 

Action Plan and the Juan de Fuca International Marine Ecosystem Initiative are all ocean 

management frameworks within which OCNMS plays an important role. In this way, the FMP

complements and emphasizes the importance of these larger collaborative frameworks.

1.4 OCNMS GOALS AND OBJECTIVES

As part of the MPR process, OCNMS worked with the AC and IPC to revise its goals and 

objectives. The revised goals and objectives presented below were adopted by OCNMS in 

September 2009 (Table 1).

Table 1 Olympic Coast National Marine Sanctuary Goals and Objectives

A. Build and strengthen OCNMS’ partnerships with the coastal treaty tribes and the Olympic Coast Intergovernmental 

Policy Council (IPC), and honor the sanctuary’s treaty trust responsibility.

Objective 1: Promote a transparent, cooperative and coordinated management structure for Olympic Coast marine 

resources within tribal, state and federal jurisdictions. 

Objective 2: Work with the four coastal treaty tribes to improve the government-to-government consultation 

process. 

Objective 3: Work collaboratively with the IPC to identify common goals and reach consensus on management 

priorities within the boundaries of the OCNMS for the protection, management and sustainable use of natural 

resources, and the promotion of educational opportunities and scientific research. 

Objective 4: Work with the IPC to improve communication and facilitate the exchange of information to foster more 

effective decision-making.

B. Promote collaborative and coordinated management and stewardship of resources in the sanctuary. 

Objective 1: Actively encourage the State, tribes, interested agencies, coastal communities, and organizations to 

partner in addressing specific sanctuary management concerns, joint work on action plans, and marine 

stewardship and sustainable use opportunities.

Objective 2: Improve intra-agency partnerships within the National Oceanic and Atmospheric Administration.

Objective 3: Create linkages between OCNMS’ action plans and ocean initiatives of other entities.

Objective 4: Maintain and support the OCNMS Advisory Council.

C. Investigate and enhance the understanding of ecosystem processes, and inform ecosystem-based management 

efforts, through scientific research, monitoring, and characterization. 

Objective 1: Understand the effects of changing climate and ocean conditions on sanctuary ecosystems. 

Objective 2: Monitor key resources within the sanctuary to identify significant changes over time.

Objective 3: Characterize and map the sanctuary’s species and habitats.

Objective 4: Promote more informed management by improving opportunities and mechanisms for sharing 

scientific data and research results.
6

INTRODUCTION

Table 1 (continued) Olympic Coast National Marine Sanctuary Goals and Objectives

C. (continued)

Objective 5: Collaborate with the IPC and coastal treaty tribes on research and monitoring activities within the 

tribes’ usual and accustomed areas. 

Objective 6: Promote and coordinate scientific research in the sanctuary in collaboration with others.

D. Enhance Ocean Literacy, promote awareness of the sanctuary and foster a sense of ocean stewardship through 

outreach, education, and interpretation efforts. 

Objective 1: Collaborate to enhance K-12 and adult education programs on the Olympic Peninsula related to 

marine ecology and conservation. 

Objective 2: Promote and support community-based conservation and education efforts. 

Objective 3: Improve the public’s understanding of coastal tribal cultures and awareness of the sanctuary and its 

marine ecosystem. 

E. Maintain the sanctuary’s natural biological diversity and protect, and where appropriate, restore and enhance 

sanctuary ecosystems. 

Objective 1: Work collaboratively with strategic partners to conserve natural habitats, populations, and ecological 

processes by preventing, minimizing and/or mitigating stressors on resources in the sanctuary. 

Objective 2: Actively participate in regional spill prevention, contingency planning, emergency response, damage 

assessment, and restoration activities. 

Objective 3: Develop and maintain permitting and enforcement programs and partnerships to maximize protection 

of resources in the sanctuary.

Objective 4: Promote marine debris removal in coordination with federal, state, local, and tribal authorities and 

volunteer organizations.

F. Enhance understanding and appreciation of the Olympic Coast’s maritime heritage (living cultures, traditions, and 

cultural resources). 

Objective 1: Map and interpret cultural resources in the sanctuary.

Objective 2: Improve understanding of and education about regional tribal cultures. 

Objective 3: Incorporate local and customary knowledge into sanctuary programs.

G. Facilitate wise and sustainable use in the sanctuary to the extent that such uses are compatible with resource 

protection. 

Objective 1: Assess, monitor and manage, as appropriate, levels of human use in the sanctuary.

Objective 2: Create and support programs and strategies that protect tribal welfare. 

Objective 3: Understand the sanctuary’s socioeconomic values. 

H. Build, maintain, and enhance an operational capability and infrastructure.

Objective 1: Ensure that OCNMS regulations are consistent with other sanctuaries, where appropriate.

Objective 2: Pursue the infrastructure improvements and staffing increases necessary to achieve the work 

identified in the management plan.

Objective 3: Identify strategies to minimize the contribution of sanctuary operations to climate change. 

Objective 4: Support and expand volunteer opportunities at the sanctuary.

Objective 5: Improve communication and collaboration between sanctuaries to share best practices.
7

TREATY TRUST RESPONSIBILITY

2 TREATY TRUST RESPONSIBILITY

From left, Vivian Lee, Hoh tribal chairman; Micah McCarty, Makah tribal chairman; Washington Gov. Chris 

Gregoire; Daniel Basta, director of NOAA’s Office of National Marine Sanctuaries; Scott Rayder, NOAA Chief 

of Staff (standing); Chris Morganroth, Quileute tribal policy representative; and Fawn Sharp, Quinault Indian 

Nation tribal chairman complete the signing of the charter to create the Intergovernmental Policy Council

(May 2007)

This section was prepared by a working group of tribal and NOAA ONMS representatives to 

provide background information for NOAA‟s policies, operations, program planning and 

program implementation that assists in satisfying the requirements of the federal trust 

responsibility to the sovereign tribal governments of the Hoh, Makah, Quileute tribes and the 

Quinault Nation (collectively the Coastal Treaty Tribes).

NOAA seeks to work directly with the Coastal Treaty Tribes on a government-to-government 

basis to promote a healthy ecosystem in the waters adjacent to the Olympic Peninsula for the 

support and enhancement of tribal treaty rights and resources, cultural resources and activities, 

tribal self-determination and sovereignty. In addition, NOAA supports and works with the 

Olympic Coast Intergovernmental Policy Council (IPC) to obtain guidance and the collective 

views of the Coastal Treaty Tribes and the state of Washington on maintaining a healthy marine 

ecosystem in the waters off the Olympic Peninsula for the benefit of all citizens and for future 

generations. NOAA believes these activities are mutually supportive of both the federal 

government‟s treaty trust responsibility as well as its responsibilities under the National Marine 

Sanctuaries Act (NMSA). 
8

TREATY TRUST RESPONSIBILITY

2.1 COASTAL TREATY TRIBES, THE TREATY RIGHT TO FISH, AND 

THE MAGNUSON-STEVENS FISHERY CONSERVATION ACT

The marine ecosystem off the Olympic Peninsula provides habitat for a wide variety of marine 

and terrestrial birds, fish, mammals and plants. Through treaties with the United States, the 

Coastal Treaty Tribes reserved hunting, fishing, and gathering rights to access and utilize the 

plants, mammals, fish and other resources of the Olympic Peninsula and its adjacent waters in 

their respective treaty areas in perpetuity. The marine ecosystem and its associated natural 

resources form an essential foundation for the economies and cultures of the Coastal Treaty 

Tribes, and the Coastal Treaty Tribes view the continued ability to harvest and utilize water, 

plants, mammals, fish and other resources of this region as being critical to the protection of their 

treaty rights and the continuity of their distinct societies. 

The treaties of the Coastal Treaty Tribes are part of the “Stevens treaties.” These treaties were

negotiated in the mid-1850s throughout the lands that are now western Washington with 

Governor of the Washington territory, Isaac Stevens. The 1855 Treaty of Neah Bay with the 

Makah Indian Tribe and the 1855 Treaty of Olympia with the Hoh Indian Tribe, Quileute Indian 

Tribe and the Quinault Indian Nation govern the relationships between the federal government 

and the Coastal Treaty Tribes.

In the 1970s American Indian tribes in the state of Washington sought to have greater access to 

their treaty resources and uphold their treaty rights in federal court. The outcome of this arduous 

legal path re-established these treaties as the supreme law of the land and culminated in the 

seminal case of United States v. Washington, written by Judge George Boldt and often referred 

to as the “Boldt” decision. (U. S. v. Washington, 384 F. Supp. 312, 353(W.D. Wash. 1974), aff’d 

520 F.2d 676 (9th Cir. 1975), aff’d sub nom. State of Washington et al. v. Washington State 

Commercial Passenger Fishing Vessel Association et al. 443 U.S 658, 99 Ct. 3055 (1979)). In 

arriving at the decision upholding the treaty rights, Judge Boldt traced the history of the salmon 

fishing tribes of the state of Washington to treaty-time signing periods. Judge Boldt‟s decision 

recounts:

“From the earliest known times, up to and beyond the time of the Stevens’ 

treaties, the Indians comprising each of the treating tribes and bands were 

primarily a fishing, hunting, and gathering people dependent almost entirely upon 

the natural animal and vegetative resources of the region for their subsistence 

and culture.” 384 F. Supp 312, 406 (W. D. Wash. 1974)

“The treaty-secured rights to resort to the usual and accustomed places to fish 

were a part of larger rights possessed by the treating Indians, upon the exercise 

of which there was not a shadow of impediment, and which were nor much less 

necessary to their existence than the atmosphere they breathed. The treaty was 

not a grant of rights to the treating Indians, but a grant of rights from them, and a 

reservation of those not granted.” 384 F. Supp. 312, 407 (W. D Wash. 1974).

The treaty right to fish is constrained only by the requirement to ensure fishery resources are 

preserved and maintained. U.S. v. Washington, 384 F. Supp. 312, 402 (W.D. Wash. 1974). 

Further, the Coastal Treaty Tribes‟ fishing rights are:
9

TREATY TRUST RESPONSIBILITY

“ ...not limited as to species of fish, the origin of fish, the purpose or use, or the 

time or manner of taking except to the extent necessary to achieve preservation of 

the resource and to allow non-Indians an opportunity to fish in common with 

treaty right fishermen outside the reservation boundaries.” 384 F. Supp. 312, 

401(W.D. Wash. 1974). 

The state of Washington may regulate tribal fisheries only in very limited circumstances:

“The State’s police power to regulate the off-reservation fishing activities of 

members of the treaty tribes exists only to the extent necessary to protect the 

fishery resource. This power does not include the authority to impair or qualify 

the treaty right by limiting its exercise to State-preferred times, manners or 

purposes except as such limitations may be necessary for preservation of the 

resource and protection of the interests of all those entitled to share it. This 

power does not include the power to determine for the Indian tribes what is the 

wisest and best use of their share of the common resource.” 384 F. Supp. 401-

402. (W.D. Wash. 1974). 

Circumstances under which the United States may limit the exercise of the treaty right are 

broader than the State‟s. Congress has plenary authority to modify the exercise of American 

Indian treaty rights through the enactment of laws and statutes, subject to Constitutional 

limitations. The federal courts are very reluctant to interpret federal statutes as abrogating or

modifying an Indian treaty absent an explicit statement by Congress to do so. In its role as comanager of the ocean fisheries, the United States acts in concert with the Coastal Treaty Tribes 

to preserve and maintain marine resources for future generations.

Because the Coastal Treaty Tribes‟ right to fish is held “in common with” the non-Indian 

citizens of present-day Washington and Oregon, Judge Boldt determined the tribes are “comanagers” of the fishery resource (U. S. v. Washington, 384 F. Supp. 312, 403 (W. D. Wash. 

1974)). Thus, each of the Coastal Treaty Tribes regulates and controls tribal fishing at its 

usual and accustomed grounds in accordance with tribal law and judicially prescribed fishery 

management responsibilities, maintains its own fisheries management and enforcement staff, 

enters into management agreements with other co-managers, and engages in a wide variety of 

research, restoration and enhancement activities to improve the scientific basis for resource 

stewardship. 

In state waters, the Coastal Treaty Tribes are co-managers of the fishery with the state of 

Washington. In federal waters (beyond three miles off shore), the Coastal Treaty Tribes are comanagers with the federal government through the implementation of the Magnuson Stevens 

Fishery Conservation Act (Magnuson Stevens Act; 16 U.S. 1801et seq.) by NOAA‟s National 

Marine Fisheries Service (NMFS). This tribal/federal/state co-management framework has 

evolved as a reliable planning forum for all aspects of fishery management, including but not 

limited to planning harvest time, place and manner, and constraining fishing mortality. The comanagers are charged with the responsibility for managing all aspects of fishery resources and 

for coordinating their efforts through the development, adoption and implementation of fishery 

management plans under the Magnuson Stevens Act. The NMSA provides authority for the 
10

TREATY TRUST RESPONSIBILITY

ONMS to regulate activities in marine sanctuaries for comprehensive and coordinated 

conservation and management in a manner which complements existing regulatory authorities 

(15CFR 922.2(b)(2)) and to develop and implement coordinated management plans for the 

protection and management of the sanctuary together with the state of Washington and the 

Coastal Treaty Tribes (15 CFR 922.2(b)(6)). 

Over the years, the federal courts have become the chief protectors of the exercise of American 

Indian treaty rights and many cases and sub-proceedings have been brought in Washington and 

Oregon courts to interpret tribal rights under the Stevens‟ treaties. In the 1990s, the United 

States Government, in exercise of its trust responsibility, asked the federal courts to establish the 

rights of Stevens‟ treaty tribes in western Washington to access shellfish beds across private 

lands and to an equitable harvest of the shellfish resource (U. S. v Washington, 873 F. Supp. 

1422 (W. D. Wash. 1994), aff’d in part, rev’d in part, 135 F.3d 618 (9th Cir. 1998), amended 

157 F. 3d 630 (9th Cir. 1998), cert. den., 526 U.S. 1060 (1999)). The resulting decision 

established the tribal right to harvest not just shellfish, but also any species of fish, finned or not 

finned, in the usual and accustomed area of a tribe. In recent years, the United States has sought 

to ensure the State of Washington does not allow the treaty fishery resource to be adversely 

impacted by state-sanctioned activities impeding fish migration and production and diminishing

the available fish resource (U. S. v Washington, (CV9213RSM August 22, 2007) 2007 WL 

2437166 (W. D. Wash. 2007) (also known as the Culverts Case)). 

2.2 OCNMS AND TRIBAL TRUST AND TREATY RESPONSIBILITIES

NOAA‟s implementation of the NMSA and its duty to implement the federal trust responsibility 

toward American Indian tribes complement and support one another. The purposes and policies 

of the NMSA include the following, “to maintain the natural biological communities in national 

marine sanctuaries, and to protect, and where appropriate restore and enhance natural habitats, 

populations, and ecological processes.” This statutory mission supports NOAA‟s

implementation of its trust responsibility for the protection of treaty trust resources, tribal access 

to treaty resources and the sustainable development of treaty rights. One of the purposes and 

policies of the NMSA is “to develop and implement coordinated plans for the protections and 

management of [sanctuaries] with ...Native American Tribes and organizations...and other 

public and private interests concerned with the continuing health and resilience of these marine 

areas.” This policy statement in the NMSA supports OCNMS‟ efforts to defer to tribal 

management plans that achieve the statutory mission and obligations of OCNMS. 

Finally, the NMSA‟s objective “to facilitate to the extent compatible with the primary objective 

of resource protection, all public and private uses of the resources of” national marine 

sanctuaries supports implementation of NOAA‟s trust responsibility to protect the exercise of 

treaty rights, now and in perpetuity. The NMSA and the federal trust responsibility provide one 

basis, among many, for the determination OCNMS regulations do not restrict the ability of 

Coastal Treaty Tribes to exercise their treaty protected rights (15 CFR 122.152(f)). The Coastal 

Treaty Tribes and NOAA strive to develop joint activities and projects, and to engage in the 

collaborative development and implementation of coordinated plans for the management and 

protection of treaty resources, to ensure resilience of those resources, and to promote the 

continuing health of the OCNMS ecosystem. 
11

TREATY TRUST RESPONSIBILITY

In summary, to the extent consistent with federal law, NOAA implements its trust responsibility 

toward the Coastal Treaty Tribes and discharges its statutory mission under the NMSA to:

 Protect and conserve treaty trust resources;

 Protect the exercise of treaty rights by the Coastal Treaty Tribes;

 Support the development of and deference to tribal treaty resource management plans

meeting the objectives of the NMSA; and

 Consult with the Coastal Treaty Tribes on a government-to-government basis when 

proposing to take an action that may affect treaty resources or tribal treaty rights or 

resources of cultural or historical significance (15 CFR 922.153(g)(h)).

2.3 CONSULTATION WITH COASTAL TREATY TRIBES

Executive Orders 12875 and 13175 (Appendices D and I) direct federal agencies to consult with 

Native American tribes on a “government-to-government” basis when proposing to take an 

action affecting tribal sovereignty or tribal trust resources or tribal treaty rights. Executive Order 

13175 also requires federal agencies to encourage American Indian tribes to develop their own 

policies to achieve program objectives, defer to tribally established standards, and preserve the 

prerogatives and authority of Indian tribes to the extent permitted by federal law. Executive 

Order 12898 (Appendix E) on Environmental Justice, specifies that federal agencies must ensure 

that environmental justice requirements are applied to American Indian tribes and their 

subsistence consumption of fish and wildlife. These policies are also reflected in the Department 

of Commerce American Indian and Alaska Native Policy, 1995 (Appendix J) and in Secretarial 

Order 3206, American Indian Tribal Rights, Federal-Tribal Trust Responsibilities and the 

Endangered Species Act (Appendix F).

Whenever it is determined by a Coastal Treaty Tribe or NOAA that actions proposed or 

authorized by the NMSA may impact tribal trust resources, the exercise of tribal treaty rights, 

Indian lands, or tribal self- government and determination, NOAA will consult with, and seek the 

participation of, the affected Coastal Treaty Tribe(s) in accordance with the executive orders and 

other agency guidance relating to such consultation. 

2.4 TRIBAL CONSULTATION PROCEDURES

Tribal consultations are planned, structured meetings between the OCNMS superintendent or 

Director of ONMS and the affected tribe(s) or their designees. They refer to meetings, either in 

person or via phone/video teleconference, between officials of ONMS and the affected tribe(s) or 

their designees, which are planned, structured and understood by both parties to be consultation. 

Communications outside of consultation meetings may be part of the overall consultation 

process, but these communications are not consultations themselves. 

As used in this document, tribal consultation means the process of seeking, discussing, and 

considering the views of the tribal government(s) at the earliest time in ONMS‟ decision-making

about the management of OCNMS. Tribal consultation is more than simply providing 

information about what ONMS is planning to do and allowing comment. Rather, tribal 

consultation means respectful, meaningful, and effective two-way communication that works 

towards the goal of consensus reflecting the concerns of the affected Coastal Treaty Tribe(s) 
12

TREATY TRUST RESPONSIBILITY

before ONMS makes its decision or moves forward with its action. The objective is to promote 

cooperative decision making on activities that may impact treaty trust resources or the exercise 

of tribal rights on American Indian lands and waters.

Individual Coastal Treaty Tribes may choose to work with ONMS to develop more specific, 

individually defined tribal consultation procedures beyond those outlined here. The tribal 

consultation procedures outlined above reflect the guiding objective and basic process that will 

be enacted. These procedures may be modified as a result of the Department of Commerce

Consultation Procedures initiative being conducted in response to Executive Order 13175

(Appendix I). 
13

PURPOSE AND NEED FOR REVISING THE MANAGEMENT PLAN AND REGULATIONS

3 PURPOSE AND NEED FOR REVISING THE 

MANAGEMENT PLAN AND REGULATIONS

3.1 PURPOSE

The purpose for taking action to address the need described below is derived principally from

the National Marine Sanctuaries Act (NMSA) and the goals and objectives for Olympic Coast 

National Marine Sanctuary (OCNMS). 

3.1.1 National Marine Sanctuaries Act

The National Marine Sanctuaries Act (NMSA, 16 U.S.C. § 1431 et seq.) is the legislative 

mandate governing the Office of National Marine Sanctuaries (ONMS) and the National Marine 

Sanctuary System (NMSS). Under the NMSA, the Secretary of Commerce is authorized to 

designate and manage areas of the marine environment as national marine sanctuaries. Such 

designations are based on attributes of special national significance, including conservation, 

recreational, ecological, historical, scientific, cultural, archaeological, educational, or aesthetic 

qualities. With the primary mandate to provide protection for the resources of these special 

ocean and Great Lakes areas, the NMSA identifies nine purposes and policies1:

(1) To identify and designate as national marine sanctuaries areas of the marine 

environment which are of special national significance and to manage these areas 

as the National Marine Sanctuary System; 

(2) To provide authority for comprehensive and coordinated conservation and 

management of these marine areas, and activities affecting them, in a manner 

complementary to existing regulatory authorities; 

(3) To maintain the natural biological communities in the national marine 

sanctuaries, and to protect, and, where appropriate, restore and enhance natural 

habitats, populations and ecological processes; 

(4) To enhance public awareness, understanding, appreciation, and wise and 

sustainable use of the marine environment, and the natural, historical, cultural and 

archeological resources of the National Marine Sanctuary System; 

(5) To support, promote and coordinate scientific research on, and long-term 

monitoring of, the resources of these marine areas; 

(6) To facilitate to the extent compatible with the primary objective of resource 

protection, all public and private uses of the resources of these marine areas not 

prohibited pursuant to other authorities; 

 

1 The purposes and policies of the NMSA have changed over time. They are presented here in their current form. 

Since NOAA designated OCNMS in 1994, the purposes and policies have been changed twice (1996 and 2000). 
14

PURPOSE AND NEED FOR REVISING THE MANAGEMENT PLAN AND REGULATIONS

(7) To develop and implement coordinated plans for the protection and 

management of these areas with appropriate Federal agencies, state and local 

governments, Native American tribes and organizations, international 

organizations, and other public and private interests concerned with the 

continuing health and resilience of these marine areas; 

(8) To create models of, and incentives for, ways to conserve and manage these 

areas, including the application of innovative management techniques; and 

(9) To cooperate with global programs encouraging conservation of marine 

resources. 

The NMSA also states the ONMS shall “maintain for future generations the habitat and 

ecological services of the natural assemblage of living resources that inhabit [sanctuaries]” (16 

U.S.C. 1431 et seq., §301(a)(4)(A),(C)). The NMSA further recognizes “while the need to 

control the effects of particular activities has led to enactment of resource-specific legislation, 

these laws cannot in all cases provide a coordinated and comprehensive approach to the 

conservation and management of the marine environment” (16 U.S.C. 1431 et seq., §301(a)(3)). 

Accordingly, the ONMS subscribes to a broad and comprehensive management approach to 

meet the NMSA‟s primary mandate of resource protection. This approach differs from various 

other national and local agencies and laws directed at managing single or limited numbers of 

species, habitats, or specific human activities within the marine environment.

Sanctuary management, therefore, serves as a framework for providing long-term protection of a 

wide range of living and non-living marine resources, while allowing multiple uses of the 

sanctuaries to the extent that they are compatible with resource protection. The ecosystems 

managed by the ONMS span diverse geographic, administrative, political and economic 

boundaries. To comprehensively manage national marine sanctuaries, individually and as a 

system, strong partnerships between the ONMS and local, state and tribal governments, resource 

management agencies, the scientific community, stakeholders and the public at-large are needed 

to achieve the coordination and program integration called for by the NMSA. The proposed 

revised management plan would enable sanctuary staff to manage the ecosystem resources of the 

sanctuary more effectively and transparently by building stronger partnerships and providing the 

public with a management plan that identifies sanctuary priorities in great detail.

3.1.2 Olympic Coast National Marine Sanctuary

OCNMS encompasses approximately 2,408 square nautical miles of coastal and ocean waters

and the submerged lands thereunder, off the central and northern coast of the state of 

Washington. In designating and managing OCNMS, NOAA‟s mission is to protect the Olympic 

Coast‟s natural and cultural resources through responsible stewardship; to conduct and apply 

research to preserve the area‟s ecological integrity and maritime heritage; and to promote 

understanding through public outreach and education. In preparation for a review of this 

management plan, OCNMS staff worked with the OCNMS Advisory Council (AC) and the 

Olympic Coast Intergovernmental Policy Council (IPC) to update the OCNMS goals and 

objectives, which are presented in section 1.3 of this document. The proposed revised 

management plan would more clearly align management priorities with the revised goals and 

objectives for the sanctuary. 
15

PURPOSE AND NEED FOR REVISING THE MANAGEMENT PLAN AND REGULATIONS

3.1.3 Management Plan Review

New challenges and opportunities emerge 

with time. To ensure sanctuary management 

keeps up with the pace of change, Section 

304(e) of the NMSA requires periodic 

updating of sanctuary management plans to 

re-evaluate site-specific goals and objectives 

and to develop management strategies and 

activities to ensure the sanctuary best protects 

its resources. As an outcome of the 

management plan review (MPR) process, 

NOAA may need to revise the regulations for 

the sanctuary to ensure they meet the 

sanctuary goals and objectives and the 

purposes and policies of the NMSA. 

3.2 NEED

Since 1994, there have been several developments which make the revision of the original 

OCNMS management plan a necessity if OCNMS is to have a management plan meeting the 

requirements presented in section 3.1 (Purpose). The various needs for such a revised 

management plan are described below.

3.2.1 Outdated Management Plan

OCNMS‟ current management plan was drafted in advance of sanctuary designation in 1994. 

The current management plan was written to give broad, general direction for the formation of 

OCNMS‟ program areas. Many of the activities it describes are too general to provide useful 

guidance now OCNMS is over a decade old (e.g., “Focus and coordinate data collection efforts 

on the physical, chemical, geological and biological oceanography of the Sanctuary”). Sixteen 

years after sanctuary designation, OCNMS is in need of more refined and directed guidance. 

Additionally, as our knowledge about the sanctuary and its resources has improved over the past 

16 years, several topics have emerged that are not addressed in the current management plan. 

For example, the current management does not directly address cultural or maritime heritage 

resources, nor does it specifically acknowledge traditional ecological knowledge from American 

Indian cultures. It also does not mention or address ecologically important resources in the 

sanctuary that have only recently been discovered, such as deep sea corals. 

3.2.2 Changes in Ocean Governance

Since 1994, there have been significant discussions focused on ocean governance issues 

nationwide in the United States, as well as regionally on the West Coast, statewide in 

Washington, and locally on the Olympic Coast. Resulting changes in local, state, regional and 

national frameworks for ocean governance are not reflected in OCNMS‟ current management 

plan. 

The Management Plan Review (MPR) 

process includes five fundamental 

steps:

1) Public scoping to identify a broad range of 

issues and concerns related to 

management of the sanctuary; 

2) Analysis and prioritization of the issues 

raised during scoping; 

3) Preparation of the draft management plan 

and relevant environmental analysis; 

4) Public comment on the draft plan and 

environmental analysis; and 

5) Revision and preparation of the final 

management plan and environmental 

analysis.
16

PURPOSE AND NEED FOR REVISING THE MANAGEMENT PLAN AND REGULATIONS

In 2003 and 2004, two major commissions, the Pew Oceans Commission and the U.S. 

Commission on Ocean Policy, addressed diverse ocean issues including ocean governance. 

The reports produced by these commissions served as impetus for the governors of California, 

Oregon and Washington to develop the West Coast Governors' Agreement on Ocean Health, 

which was released on September 18, 2006 (http://westcoastoceans.gov/docs/WCOcean

Agreementp6.pdf). This agreement launched a new, proactive, regional collaboration to protect 

and manage the ocean and coastal resources along the entire West Coast.

On December 31, 2006, the Washington State Ocean Policy Work Group, under direction from 

the Washington State Legislature completed the Washington Ocean Action Plan. Since that time 

the Governor's Office and state agencies have been acting on the plan‟s recommendations

through the State Ocean Caucus. The State Ocean Caucus provides a way for state agencies to 

work together to prioritize activities and solve problems related to the ocean environment of 

Washington state.

In 2007, the Hoh, Makah, Quileute tribes, the Quinault Indian Nation, the state of Washington 

and OCNMS collaborated to form the Olympic Coast Intergovernmental Policy Council (IPC). 

The first of its kind in the nation, the IPC provides a regional forum for marine resource 

managers to exchange information, coordinate policies, and develop recommendations for 

resource management within the sanctuary.

On a local level, in 2009, the Washington Department of Fish and Wildlife, directed by the 

Washington State Legislature, worked with Washington‟s five coastal counties to create a 

Coastal Marine Resource Committee (MRC) Program. The goal of the MRC Program is to 

understand, steward, and restore the marine and estuarine ecological processes of the 

Washington coast in support of ecosystem health, sustainable marine resource-based livelihoods, 

cultural integrity, and coastal communities. Two of the coastal MRCs formed are adjacent to 

OCNMS: the North Pacific Coast MRC and Grays Harbor MRC. These MRCs represent a new 

grassroots, local, community-based marine stewardship effort not envisioned in 1994. 

While the original 1994 OCNMS management plan allows for OCNMS to pursue partnerships 

with other organizations and ocean management initiatives, by revising the management plan, 

OCNMS can elucidate more specifically its role in these multiple new collaborative ocean 

management frameworks in the Olympic Coast region.

3.2.3 Data Gaps

In September 2008, OCNMS published a Condition Report on the status and trends for resources 

within the sanctuary. This report found, in general, the resources within the sanctuary appear to 

be in good to fair condition, which may in large part be a reflection of the sanctuary‟s isolation 

from major urban areas and industrial complexes. The 2008 Condition Report also identified 

significant data gaps in existing knowledge about resources in the sanctuary. Currently only 

25% of the seafloor habitat in the sanctuary has been accurately mapped and characterized. 

There is also limited understanding of some fisheries resources, current patterns of exploitation, 

and overall marine ecosystem functioning in the sanctuary. Furthermore, there is limited 

understanding of phenomena recently observed in the sanctuary (e.g., hypoxia, ocean 

acidification) that may be related to climate change. The Condition Report also emphasized the 

critical need for an ecosystem-based approach to research and monitoring in the sanctuary. 
17

PURPOSE AND NEED FOR REVISING THE MANAGEMENT PLAN AND REGULATIONS

While there was a general research and monitoring component in the original 1994 management 

plan, the data gaps identified in the 2008 Condition Report indicate a much more detailed and 

comprehensive suite of research and monitoring strategies are needed to guide management of 

OCNMS. 

3.2.4 New Technologies

There have been significant improvements in technology related to habitat mapping, ocean 

exploration, water quality monitoring and other data collection efforts that have increased the 

capacity of NOAA and its partners‟ research and monitoring programs. None of these new 

technologies are mentioned in the original 1994 management plan. In revising the management 

plan, OCNMS can highlight these technologies and provide a more specific research plan for the 

next five to ten years.

3.2.5 Recent and Emerging Issues

Several ocean conservation and management issues currently at the forefront of discussions are 

not addressed in the 1994 management plan. These emerging issues include climate change, 

ocean acidification, ocean hypoxia, open ocean aquaculture, and alternative energy development. 

By revising the OCNMS management plan, NOAA will be able to address several of these issues 

directly. 

In particular, the revised management plan includes a physical and chemical oceanography 

action plan placing a strong emphasis on ocean acidification and hypoxia research, as well as a

climate change action plan. While the revised management plan does not include policies or 

regulations related to specific emerging ocean development uses, such as wave energy and open 

ocean aquaculture, it does include a regional ocean planning action plan, as well as focused 

strategies for OCNMS permitting and enforcement programs. Rather than instituting new 

policies or regulations related to particular types of ocean development, OCNMS‟ revised 

management plan focuses on participation in emerging regional planning efforts in order to guide 

and locate ocean development projects in a manner that best protects marine ecosystems inside 

and adjacent to the sanctuary. 

19

MANAGEMENT PLAN REVIEW PROCESS

4 MANAGEMENT PLAN REVIEW PROCESS

Management Plan Review, or MPR, is the process by which ONMS reviews and revises the 

management plans for all national marine sanctuaries. A sanctuary management plan is a sitespecific planning and management document that describes the goals, objectives and activities 

for a sanctuary, and guides future management activities. Sanctuaries are currently mandated 

under the National Marine Sanctuaries Act (NMSA) to review and, if necessary, revise their 

management plans on 5-year intervals. 

4.1 OVERVIEW OF THE MPR PROCESS

Olympic Coast National Marine Sanctuary‟s (OCNMS) MPR process consists of six distinct 

phases:

Phases I and II began in 2005, years before ONMS began the formal public scoping process. 

During Phases I and II, ONMS planned for the public phases of MPR by briefing the OCNMS

Advisory Council (AC) on details of the MPR process, developing a communications plan for 

the MPR process, and developing a detailed MPR timeline and process outline. Additionally, 

during these early phases ONMS worked with the Coastal Treaty Tribes and the state of 

Washington to form the IPC in 2007. Early work of the IPC included discussions on the 

proposed MPR process and preliminary priority topics for MPR.

The final task in Phase II was the production of the 2008 OCNMS Condition Report (ONMS 

2008). The Condition Report provided a summary of resources in the sanctuary, pressures on 

those resources, current resource conditions and trends, and management responses to the 

pressures that threaten the integrity of the sanctuary‟s marine environment. This report served as 

one source of background and supporting material for the MPR process.

Phase III, Public Scoping & Issues Analysis, was initiated when ONMS published a Notice of 

Intent (NOI) in the Federal Register (73 FR 53162; Appendix B) announcing a 60-day public 

comment period on the scope and need for conducting OCNMS‟ MPR. This NOI initiated the 

public portion of the MPR process. Phase III continued for 16 months after the close of the 

public comment period to allow for in-depth public and stakeholder involvement in analyzing the

comments received and developing a suite of priority issues to address in the revised 

management plan. Also during this phase, OCNMS went through a detailed priority issue 

Phases of the Management Plan Review Process

Phase I – Initiation (2005-2008)

Phase II – Project Planning (2005-2008)

Phase III – Public Scoping & Issues Analysis (2008-2010)

Phase IV – Develop Draft Management Plan (2010)

Phase V – Public Review (2011)

Phase VI – Issue Final Management Plan & Environmental Analysis (2011)
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MANAGEMENT PLAN REVIEW PROCESS

analysis process with the AC and the IPC, which included a series of AC working group 

meetings and workshops to explore priority issues in greater detail.

The AC working groups and workshops involved over 100 subject area experts and interested 

members of the public. Through these meetings specific strategies and activities for the revised 

management plan were developed. The AC then reviewed these suggested strategies and 

activities, recommended minor changes and voted to forward them to the OCNMS 

Superintendent with a recommendation they be included in the revised management plan.

Phase IV of the MPR process focused on developing the Draft Management Plan (DMP),

proposed regulatory changes and requisite environmental compliance documentation. ONMS 

took the strategies and activities forwarded by the AC, as well as some developed internally 

based on agency priorities, and shaped them into the 20 action plans provided in section 5.0 of 

the DMP. Staff also developed a draft environmental assessment (DEA) to analyze the 

environmental impacts of the DMP, as required under the National Environmental Policy Act 

(NEPA). Lastly, ONMS developed changes to the OCNMS regulations in order to implement

several activities identified in the DMP. The regulatory changes were published separately 

through a notice of proposed rulemaking in the Federal Register (76 FR 2611). The publication 

of the DMP, DEA and the notice of proposed rulemaking marked the end of Phase IV and 

beginning of Phase V of the MPR. 

Phase V, public review of the DMP/DEA, occurred from January 14 to March 25, 2011, and 

included public hearings and receipt of written comments. Phase VI was finalization of the 

management plan and environmental compliance documentation in response to comments 

received, which led to this final management plan and environmental assessment document 

(FMP/EA). All documents produced as part of the MPR process can be found on-line at

http://olympiccoast.noaa.gov/.

4.1.1 Public Involvement

There has been continual and significant public involvement in the MPR process and the 

development of the FMP. Nationwide, the ONMS MPR process is driven largely by the input of 

sanctuary advisory councils, members of the public and topic area experts. ONMS has strived 

throughout the MPR process to offer its partners and the public numerous opportunities to 

contribute to and shape the revised management plan.

During Phase III of MPR, Public Scoping and Issues Analysis, ONMS encouraged public 

involvement by:

 Hosting seven public scoping meetings in Port Angeles, Neah Bay, La Push, Westport, 

Ocean Shores, Olympia and Seattle;

 Holding a 60-day public comment period during which members of the public could 

submit MPR comments via e-mail, fax or letter;

 Hosting 23 additional public meetings related to MPR, including AC meetings, 

workshops and working group meetings;

 Posting approximately 20 updates to OCNMS‟ MPR Current Status website 

(http://olympiccoast.noaa.gov/) to keep the public informed about the MPR process;
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MANAGEMENT PLAN REVIEW PROCESS

 Sending approximately 20 updates to the OCNMS MPR listserv, which has over 1,000 

members; and

 Making all MPR documents available on the OCNMS MPR Documents webpage in a 

timely manner (http://olympiccoast.noaa.gov/).

Public attendance at bi-monthly AC meetings has varied throughout the MPR process. Usually, 

a minimum of one or two members of the public were present at any given meeting. At meetings 

during which major MPR decisions were made, upwards of 20 members of the public attended. 

Additionally, a few individuals expressed participated in AC working group meetings and 

workshops held during Phase IV, development of the draft management plan. 

Throughout phases III, IV and V, ONMS informed the public about MPR-related meetings by 

sending out press releases and listserv e-mails, and posting notices on its website in advance of 

every public meeting. Additionally, OCNMS staff actively sought out opportunities to present 

information about the MPR process at various public events and meetings. ONMS also 

produced and publicized numerous documents detailing each step in the MPR process so the 

public could stay informed as progress was made. 

During Phase V, public review of the DMP/DEA, ONMS announced the availability of the 

DMP/DEA and Proposed Rule in a Federal Register notice, newspaper articles, web site updates 

and listserv e-mails. In addition, two public meetings were held in Port Angeles and Forks to 

provide opportunity for public comment. 

4.2 MPR PRELIMINARY PRIORITY TOPICS

In preparation for the public scoping process, OCNMS staff and the IPC identified six topics 

anticipated to be high priorities for consideration during the MPR process. These preliminary 

priority topics were published in the Notice of Intent (Appendix B) initiating the public scoping 

period in order to share with the public the best professional judgment of OCNMS and the IPC 

on important issues needing to be considered during MPR, and to encourage public comments on 

specific issues. Preliminary priority topics were:

1. Improved Partnerships

Recent initiatives for regional ocean management, including the formation of the 

IPC, the Washington Ocean Action Plan and the West Coast Governors 

Agreement on Ocean Health, provide the sanctuary with new opportunities to 

strengthen partnerships, particularly with the four Coastal Treaty Tribes and the 

state of Washington in their role as governments. OCNMS will work in active 

partnership to provide a more transparent, cooperative and coordinated 

management structure of Olympic Coast marine resources within tribal, state and 

federal jurisdictions.

2. Characterization and Monitoring

There is a need to develop an understanding of baseline conditions of marine 

resources and ecosystem functions of the sanctuary, and status and trends of 

biological and socioeconomic resources to effectively inform management. 

OCNMS, in conjunction with the IPC and other entities, will work to address 

these needs.
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MANAGEMENT PLAN REVIEW PROCESS

3. Spill Prevention Contingency Planning and Response

The risk from vessel traffic and other hazards remains a significant threat to 

marine resources. The potential for a catastrophic oil spill remains a primary 

concern and while advances in maritime safety have been made since the 

sanctuary was designated, better coordination is needed for response to these 

threats. Oil spills cause immediate and potentially long-term harm to marine 

resources as well as socioeconomic impacts to coastal communities.

4. Climate Change

Climate change is widely acknowledged, yet there is considerable uncertainty 

about current and future consequences at local, ecosystem and oceanic scales. 

Increased coordination and cooperation among resource management agencies is 

required to improve planning, monitoring and adaptive management to address 

this phenomenon. 

5. Ocean Literacy

Enhancing the public‟s awareness and appreciation of marine, socioeconomic, 

and cultural resources is a cornerstone of the sanctuary‟s mission. Recent 

regional initiatives offer opportunities for the sanctuary, in conjunction with the 

IPC and other entities, to expand education contributions and reach a larger 

audience.

6. Marine Debris

Coastal marine debris is a persistent and poorly diagnosed problem within the 

sanctuary negatively impacting natural and socioeconomic resources and 

qualities.

ONMS clarified in the NOI the publication of these six preliminary priority topics in no way 

restricted the content and scope of comments the public could submit. ONMS encouraged 

members of the public to submit comments on any topic or issue that they felt was important for 

ONMS to address in its revised management plan. All of the six preliminary priority topics were 

retained in the FMP, though the topic titles and characterizations were modified as a result of 

public comment and the issue prioritization process.

4.3 SUMMARY OF PUBLIC SCOPING

The 60-day public scoping comment period was open from September 15 to November 14, 2008. 

A total of 166 people attended the seven public scoping meetings, and they provided 516 

recorded comments. During the public scoping comment period, an additional 688 letters, 

e-mails and public comment forms were received, of which approximately 600 were from an 

e-mail campaign and included the same five comments. 

Many of the letters and e-mails contained comments on multiple topics, which were separated 

for analysis. The total number of unique or individual comments analyzed by ONMS staff was 

1,009 (516 from the public meetings and 493 from written comments). Staff summarized and 

analyzed these comments by grouping them under 37 topics (Table 2).
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MANAGEMENT PLAN REVIEW PROCESS

Table 2 List of 37 topics raised during scoping

Public Scoping Topics (in alphabetical order)

1 Administration - Flexibility to Respond to Emerging Issues

2 Administration -Infrastructure

3 Administration - Sanctuary Goals & Objectives

4 Boundary Adjustment

5 Climate Change

6 Collaborative and Coordinated Management

7 Community Outreach

8 Ecosystem Impacts of Fishing

9 Fisheries Stock Assessment

10 Habitat Characterization

11 Habitat Protection

12 Invasive Species

13 Living Resource Conservation

14 Living Resources Monitoring

15 Local and Customary Knowledge

16 Marine Debris - Abandoned Submerged Equipment

17 Marine Debris - Shoreline Clean-Up

18 Maritime and Environmental Safety - Harbors of Refuge

19 Maritime and Environmental Safety - Navigation

20 Maritime and Environmental Safety - Vessel Management

21 Maritime and Environmental Safety - Weather Forecasting

22 Maritime Heritage - Cultural Resource Management

23 Maritime Heritage - Living Cultures

24 Military Activities

25 Non-point Source Pollution

26 Ocean Literacy

27 Public and Private Resource Use - Commercial Development

28 Public and Private Resource Use - Compatibility Analysis

29 Public and Private Resource Use - Recreational Opportunities

30 Public and Private Resource Use - Socioeconomic Values & Human Use

31 Regulations, Permitting & Enforcement

32 Research to Support Ecosystem Management

33 Spill Prevention, Contingency Planning and Response

34 Treaty Trust Responsibility

35 Visitor Services

36 Water Quality Monitoring

37 Water Quality Protection
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MANAGEMENT PLAN REVIEW PROCESS

Final list of priority topics, which are 

described in the Priority Issue Work 

Plan as priority issues:

A. Fulfill treaty trust responsibility

B. Achieve collaborative and coordinated 

management

C. Conduct collaborative research, assessments 

and monitoring to inform ecosystem-based 

management

D. Improve ocean literacy

E. Conserve natural resources in the sanctuary

F. Understand the sanctuary’s cultural, historical 

and socioeconomic significance

Understand the sanctuary’s cultural, 

historical and socioeconomic significance 

In December 2008, ONMS published on its website (http://olympiccoast.noaa.gov/) and 

presented to the AC and IPC:

1. All of the public comments received

2. A Scoping Summary describing the process by which the public comments were binned 

under the 37 public scoping topics, and showed which comments were binned under each 

topic

3. A Topic Analysis Report analyzing each of the 37 topics in greater detail and 

summarized the types of public comments submitted on each topic 

4.4 ISSUE PRIORITIZATION AND FINAL PRIORITY TOPICS

In January 2009, ONMS worked with the OCNMS AC and the IPC to begin the issue 

prioritization process, which was also part of Phase III, Public Scoping and Issues Analysis. To 

initiate this process, the AC hosted a two-day, facilitated Issue Prioritization Workshop in 

January 2009. IPC members were invited to participate along with AC members. The workshop 

was open to the public and members of the public were given several opportunities to comment 

during the workshop. 

In preparation for the workshop, each AC seat was asked to score each of the 37 public scoping 

topics based upon 1) benefits to sanctuary resources, 2) urgency of the topic, 3) extent to which 

the topic advances the mission and goals of the ONMS, and 4) any limiting factors that could 

prevent ONMS from successfully addressing a topic. The compiled scores were reviewed by the 

participants at the workshop. 

During the workshop, AC members made 

comments and suggestions about potential 

grouping/combining of topics, ways in which 

the topics should be characterized, and 

OCNMS‟ specific role in addressing the 

topics. By the end of the workshop, the AC 

had generated lists of 1) highest priority 

topics, 2) second-tier topics, 3) topics that 

should be grouped under other topics, and 

4) topics that should not be addressed in the 

revised management plan. A detailed 

description of the workshop and its outcomes 

can be found in the AC Issue Prioritization 

Workshop Report published in March 2009

(http://olympiccoast.noaa.gov/).

After analyzing the workshop results, ONMS drafted a Priority Issue Work Plan. The aims of 

the Priority Issue Work Plan were to 1) identify the final list of priority topics to be addressed in 

the revised management plan, and 2) identify a suite of working groups and workshops 

supported by the AC through which each priority topic would be addressed in greater detail. The 

AC and IPC were intimately involved in developing the Priority Issue Work Plan, which went 
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MANAGEMENT PLAN REVIEW PROCESS

through several iterations of review. The final Priority Issue Work Plan was the result of a 

detailed, facilitated discussion between the AC, OCNMS staff and IPC representatives at the 

May 2009 AC meeting. At that time, all parties agreed on the final list of priority topics, as well 

as the working groups and workshops the AC would host and organize. The Priority Issue Work 

Plan was published on the OCNMS website in July 2009. (http://olympiccoast.noaa.gov/).

4.5 WORKING GROUPS AND WORKSHOPS

The final stage of Phase III (public scoping and issues analysis) involved the AC sponsoring 

several working groups and workshops to address the six priority issues identified in the Priority 

Issue Work Plan. AC members and IPC members, with support from OCNMS staff, hosted the 

working group meetings and workshops between July and December 2009. It should be noted 

some priority issues were addressed solely by OCNMS staff, who reported their findings to the AC 

for review and comment. Additionally, the working group addressing treaty trust responsibility

was comprised solely of IPC and federal representatives (United States government, state of 

Washington, Hoh Tribe, Makah Tribe, Quileute Tribe and the Quinault Indian Nation). This group 

was not considered an AC working group and did not report to the AC. Below is a list of all the 

working groups and workshops, grouped under the six priority issues:

Working Groups and Workshops

Grouped under the six priority issues identified in the Priority Issue Work Plan

Fulfill treaty trust responsibility

1. Governments Working Group: Treaty Trust Responsibility

Achieve collaborative and coordinated management

2. OCNMS Staff Working Group: Collaborative and Coordinated Management

3. OCNMS Staff Working Group: Sanctuary Operations

Conduct collaborative research, assessments and monitoring to inform ecosystem-based management

4. Advisory Council Working Group: Collaborative Research, Assessments and Monitoring to Inform Ecosystem-Based 

Management 

Improve ocean literacy

5. Workshop: Ocean Literacy

Conserve natural resources in the sanctuary

6. Advisory Council Working Group: Spills Prevention, Preparedness, Response and Restoration

7. Advisory Council Working Group: Living Resources Conservation

Understand the sanctuary’s cultural, historical and socioeconomic significance 

8. Workshop: Maritime Heritage

9. Workshop: Socioeconomic Values of Resources in the Sanctuary
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OCNMS staff worked with AC members to identify subject-area experts to participate in the 

working group meetings and workshops. All working group meetings and workshops were open 

to the public with the exception of the working group addressing treaty trust responsibility. 

With the exception of the governments working group, which developed section 2.0 (Treaty 

Trust Responsibility) of this document, all working groups and workshop organizers submitted 

reports to the AC detailing their final recommendations and findings, including specific 

strategies and activities to be included in the revised management plan. Representatives from 

each working group and workshop presented their reports to the AC during its November 2009 

and January 2010 meetings. All reports were published on-line (http://olympiccoast.noaa.gov/) 

in advance of the AC meeting at which they were presented.

The AC discussed each report and voted to forward all of the strategies and activities 

recommended by the working groups/workshops, with minor changes, to the OCNMS 

Superintendent with a formal endorsement and recommendation that they be included in the 

revised management plan. The AC‟s recommendations were published on-line 

(http://olympiccoast.noaa.gov/), along with a letter of support from the AC.

4.6 ACTION PLANS

OCNMS staff took the strategies and activities recommended by the AC and used them to 

develop a suite of 20 action plans:

A. Achieve Effective Collaborative and Coordinated Management

A1. Collaborative and Coordinated Sanctuary Management Action Plan

A2. Community Involvement in Sanctuary Management Action Plan

A3. Sanctuary Operations Action Plans

B. Conduct Collaborative Research, Assessments and Monitoring to Inform Ecosystem 

Based Management

B1. Habitat Mapping and Classification Action Plan

B2. Physical and Chemical Oceanography Action Plan

B3. Populations, Communities and Ecosystems Action Plan

B4. Data Management, Sharing and Reporting Action Plan

C. Improve Ocean Literacy

C1. K-12 Education Action Plan

C2. Higher Education Action Plan

C3. Visitor Services Action Plan

C4. Community Outreach Action Plan
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D. Conserve Natural Resources in the Sanctuary

D1. Spills Prevention, Preparedness, Response and Restoration Action Plan

D2. Climate Change Action Plan

D3. Marine Debris Action Plan

D4. Wildlife Disturbance Action Plan

D5. Water Quality Protection Action Plan

D6. Habitat Protection Action Plan

D7. Regional Ocean Planning Action Plan

E. Understand the Sanctuary’s Cultural, Historical and Socioeconomic Significance

E1. Maritime Heritage Action Plan

E2. Socioeconomic Value of Resources in the Sanctuary Action Plan

ONMS staff presented the preliminary draft action plans to the AC and the IPC at their March 

2010 meetings and received comments from both councils that were used to refine the action 

plans. Between spring and fall 2010, ONMS worked to develop the Draft Management Plan and 

Draft Environmental Assessment (DMP/DEA). The DMP/DEA was available for public 

comments from January through March 2011. The final management plan and environmental 

assessment (FMP/EA) presented here is based on the January 2011 DMP/DEA, modified after 

comments from the public, agencies and governments.

4.7 IMPROVING COLLABORATION THROUGH THE MPR PROCESS

One of the most beneficial aspects of the MPR process is it has given ONMS a vehicle through 

which to build stronger relationships with its partners. Throughout the MPR process, ONMS has 

focused on improving its communications and relationships with the IPC, the AC, each Coastal 

Treaty Tribe, the Pacific Fishery Management Council (PFMC), National Marine Fisheries 

Service (NMFS), Olympic National Park, the Washington Maritime National Wildlife Refuge 

Complex, the state of Washington Ocean Caucus, the local marine resources committees and a 

host of others. 

ONMS has worked to make the MPR process transparent and inclusive of all interested partners 

with the goal of building the support necessary to implement the revised management plan in a 

collaborative manner. Given the multitude of jurisdictions overlaying the sanctuary and the 

paucity of resources of all agencies and organizations, successful marine conservation efforts in 

the sanctuary will require OCNMS to build long-term, trusting and functional partnerships 

allowing groups to pool resources, share information and manage ecosystems in an effective 

manner that protects our ocean resources for future generations.

During the MPR process, ONMS made great strides in improving relationships with its partners. 

ONMS is committed to maintaining and growing these relationships while it implements the 

management plan.
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MANAGEMENT PLAN REVIEW PROCESS

4.8 SCOPING IDEAS CONSIDERED BUT NOT DEVELOPED AS 

ALTERNATIVES

Most of the 37 topics identified through public scoping are addressed in some manner in the 

FMP (section 5). However, a few topics or particular aspects of topics raised by the public were 

not incorporated into the FMP or into the other alternatives analyzed in this document. In most 

cases, these scoping topics were eliminated from further consideration early in the MPR process. 

The reasons for their elimination are provided below. It should be noted any of these issues can 

be identified and considered again during future MPR cycles.

4.8.1 Boundary Expansion

Several public comments requested NOAA expand OCNMS‟ boundary to include the Strait of 

Juan de Fuca or additional parts of the deep sea canyons on the western edge of the current 

sanctuary boundary. ONMS decided not to pursue boundary expansion because information on 

the characteristics of the deep sea canyons is not extensive. Thus, it is too early to say whether 

these canyons warrant inclusion in the sanctuary. The expansion of the sanctuary to include the 

canyons could be considered in the future when more information is available.

4.8.2 Alternative Energy Development

ONMS received many public comments on specific types of alternative energy development in the 

sanctuary (e.g., wave energy, wind energy). Some comments were supportive of alternative 

energy development in the sanctuary, and others were opposed. Because marine spatial planning 

efforts are just getting underway nationally and regionally, ONMS decided to address ocean 

energy activities under the broad topic of marine spatial planning, and developed a regional ocean

planning action plan. ONMS plans to participate actively in state and regional ocean planning 

processes and believes alternative energy project siting is better addressed within the context of 

these larger-scale planning processes. In addition, ONMS would likely be involved in any 

offshore commercial development proposed within the sanctuary through the ONMS permitting 

process.

4.8.3 Compatibility Determinations

One of the goals of the NMSA is to facilitate human uses in sanctuaries that are compatible with the 

NMSA‟s primary mandate of resource protection. ONMS received several public comments asking 

for clarification on which and to what extent different human uses are compatible with the goals and 

objectives of OCNMS.

OCNMS‟ existing permitting regulations and procedures already provide a framework for 

evaluation of compatibility of proposed activities in the sanctuary on a case-by-case basis. Thus, 

ONMS did not opt to pursue development of a detailed compatibility or more holistic

determination process at this time.

4.8.4 No-take Zones/Marine Reserves

ONMS received multiple public comments requesting the establishment of fishing and boating 

bans in the sanctuary, including “no-take zones,” marine reserves, bottom trawling bans, and 

motorized boating bans. In general, these comments reflect a desire for stronger resource 

protection and conservation efforts in the sanctuary. In the FMP, ONMS has addressed the need 
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MANAGEMENT PLAN REVIEW PROCESS

for improved conservation and protection through seven action plans focusing on spills, climate 

change, marine debris, wildlife disturbance, water quality protection, habitat protection and 

regional ocean planning. Given the regulatory and political complexity of the process, ONMS 

decided it would not initiate action on or explore the specific topic of creating no-take zones or 

marine reserves (both terms describe areas where all extractive activities, including fishing, are 

prohibited) as part of this MPR process. ONMS is, however, working to identify locations of 

habitats in the sanctuary that are important for various life stages of fish and other marine 

organisms, will share this information with other management authorities, and will continue to 

work within the context of existing fishery management frameworks to ensure fishing practices 

are compatible with sustainable fisheries in the sanctuary.

4.8.5 Aquaculture Ban

During the public scoping period, ONMS received comments requesting aquaculture be banned 

in the sanctuary. Some comments focused on the potential adverse impacts associated with 

farming Atlantic salmon, a non-native species. Since sanctuary designation no aquaculture 

permit applications have been received nor issued by the OCNMS Superintendent, and no 

aquaculture activities are known to occur within sanctuary boundaries.

ONMS has addressed one aspect of the aquaculture issue in alternative C (section 7), which 

includes the consideration of a regulatory ban on the introduction of invasive species in the 

sanctuary. Atlantic salmon and a few other cultured organisms are classified as invasive species 

by the state of Washington and, as such, project proposals with these species would receive 

rigorous scrutiny and installed facilities would require effective containment, as is the current 

practice in Washington state. Similar to the alternative energy topic, ONMS would treat any 

future aquaculture proposal as an offshore commercial development project that likely would be 

subject to the ONMS permitting process. It can be assumed any aquaculture project proposed in 

the sanctuary would require an ONMS permit based on OCNMS regulations related to seabed 

disturbance (for anchoring/mooring aquaculture structures) and discharge. While efforts are 

being made to develop aquaculture technologies not requiring seafloor anchoring (i.e., a project 

that may not be subject to ONMS permitting), such technologies are not widely used at this time 

and are unlikely to be technologically and/or economically feasible in the near future in the 

dynamic ocean conditions of the outer Washington coast. During review of an aquaculture 

project‟s permit application, ONMS would consider all the potential impacts of any proposed 

aquaculture operation. Therefore, ONMS did not pursue specific regulatory actions related to 

aquaculture in any of the alternatives in this document. In addition, appropriate siting for 

aquaculture projects should also be addressed in regional ocean planning processes, in which 

ONMS intends to participate, and be guided by NOAA‟s Aquaculture Policy and Guidance 

issued in 2011 (NOAA 2011). 

4.8.6 Harbors of Refuge

ONMS received one public comment requesting harbors of refuge be established along the outer 

coast of Washington. In the context of oil spill response, a harbor of refuge is where a 

distressed, and possibly leaking, vessel goes to control the emergency situation and possibly 

limit environmental impacts of spilled oil. This issue was not considered in the management 

plan because there are no suitable locations for harbors of refuge in the sanctuary. Furthermore, 

this issue is being addressed by the Region 10 Regional Response Team/Northwest Area 

Committee.

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FINAL MANAGEMENT PLAN

5 FINAL MANAGEMENT PLAN

5.1 INTRODUCTION

The OCNMS Final Management Plan (FMP) is comprised of a series of 20 action plans (Table

3), which are grouped under five of the six priority issues. One priority issue, Fulfill Treaty 

Trust Responsibility, is not addressed directly through an action plan but is the sole focus of 

section 2 of this document.

Table 3 Olympic Coast National Marine Sanctuary Final Management Plan Action Plans

A. Achieve Effective Collaborative and Coordinated Management.

A1. Collaborative and Coordinated Sanctuary Management Action Plan

A2. Community Involvement in Sanctuary Management Action Plan

A3. Sanctuary Operations Action Plan

B. Conduct Collaborative Research, Assessments and Monitoring to Inform Ecosystem-Based 

Management.

B1. Habitat Mapping and Classification Action Plan

B2. Physical and Chemical Oceanography Action Plan

B3. Populations, Communities and Ecosystems Action Plan

B4. Data Management, Sharing and Reporting Action Plan

C. Improve Ocean Literacy

C1. K-12 Education Action Plan

C2. Higher Education Action Plan

C3. Visitor Services Action Plan

C4. Community Outreach Action Plan

D. Conserve Natural Resources in the Sanctuary

D1. Spills Prevention, Preparedness, Response and Restoration Action Plan

D2. Climate Change Action Plan

D3. Marine Debris Action Plan

D4. Wildlife Disturbance Action Plan

D5. Water Quality Protection Action Plan

D6. Habitat Protection Action Plan

D7. Regional Ocean Planning Action Plan

E. Understand the Sanctuary’s Cultural, Historical and Socioeconomic Significance

E1. Maritime Heritage Action Plan

E2. Socioeconomic Values of Resources in the Sanctuary Action Plan
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FINAL MANAGEMENT PLAN

These action plans represent OCNMS‟ preferred alternative for its management plan revision and 

were analyzed as the preferred alternative in accordance with the National Environmental Policy 

Act (NEPA). Later in this document, sections 7 (Description of Alternatives) and eight

(Environmental Consequences of Alternatives) specifically reference the strategies and activities 

described in the FMP as the “preferred” alternative (alternative B).

Regulatory changes ONMS proposed during the management plan review (MPR) process are 

included as activities in relevant action plans, and the environmental consequences of these 

regulatory changes are analyzed, as required under NEPA, in section 8 of this document. 

In addition to the 20 action plans (section 5.2), section 5.3 provides a set of performance 

measures ONMS will use to assess its progress in implementing the new management plan. 

Section 5.4 provides cost estimates for each strategy for the first five years of management plan 

implementation; however, it is possible implementation of the management plan will extend 

beyond five years. 

The suite of strategies and activities in this FMP is ambitious and anticipated to be more than can 

be accomplished with available resources. To accommodate uncertainties associated with future 

funding and staffing levels, section 5.5 provides an implementation table (Table 5) indicating

which strategies will be high, medium, and low priorities for ONMS to implement under 

different budget scenarios.

5.2 ACTION PLANS

The twenty action plans outline the specific work ONMS will undertake over the effective life of 

this management plan, which is anticipated to be five to ten years. ONMS‟ ability to implement 

these action plans will depend primarily on its success in forming the necessary partnerships as 

well as the availability of required resources. Each action plan includes a common set of 

elements:

 Desired outcome statement;

 Links to relevant OCNMS goals (section 1.3) and other action plans;

 Background information on the topic and why it is priority for OCNMS;

 Strategies and activities; and

 List of key partners.
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FINAL MANAGEMENT PLAN

A. Achieve Effective Collaborative and Coordinated Management

A1. Collaborative and Coordinated Sanctuary Management Action Plan

A2. Community Involvement in Sanctuary Management Action Plan

A3. Sanctuary Operations Action Plans

Introduction

Collaboration and coordination are essential to achieving effective sanctuary management. Since 

OCNMS was designated in 1994, OCNMS management has fostered relationships with multiple 

government agencies, the Coastal Treaty Tribes, academic and educational institutions, local 

communities and groups involved in research, educational programming and resource protection 

efforts. The scope of these efforts has ranged from sharing information, to coordinating 

independent actions aimed at achieving a common goal, to developing close and durable 

partnerships. These efforts have enabled OCNMS management and its partners to accomplish 

far more than would have been possible by any single entity. 

Throughout the MPR process, the AC, IPC and public have repeatedly expressed the need for 

improved collaboration and coordination between OCNMS and its multitude of partners. The 

three action plans presented here outline how OCNMS intends to improve and grow its 

relationships with other governments and government entities, non-government and grassroots 

organizations and local communities over the life of the management plan.
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FINAL MANAGEMENT PLAN

A1. Collaborative and Coordinated Sanctuary Management Action Plan

Desired Outcome: Improved communication, greater collaboration and stronger relationships 

between OCNMS and other agencies and governments with jurisdiction over resources in the 

sanctuary.

Links to Goals:

Goal A - Build and strengthen OCNMS‟ partnerships with the Coastal Treaty Tribes and the IPC, 

and honor the OCNMS‟ treaty trust responsibility.

Goal B - Promote collaborative and coordinated management and stewardship of resources in the 

sanctuary.

Background:

Almost all of OCNMS‟ research, education and stewardship efforts are done in collaboration 

with other agencies and organizations. Throughout the action plans there are references to 

collaborative and coordinated efforts associated with specific strategies and activities. This 

action plan, rather than calling out all of these project-level partnerships, instead focuses on how

OCNMS will develop and improve its relationships with governments and government agencies 

at the leadership or management level. 

The focus of this action plan is on partnerships with entities having jurisdiction over resources in 

the sanctuary (Figure 2) and with which OCNMS coordinates and collaborates at a managerial 

level, including the IPC, NMFS, U.S. Coast Guard, U.S. Navy, the National Park Service, which 

manages Olympic National Park (ONP), the U.S. Fish and Wildlife Service (USFWS), which 

manages the Washington Maritime National Wildlife Refuge Complex, and Canadian 

government agencies. Active collaboration with these organizations will provide a more 

transparent and inclusive structure for management of Olympic Coast marine resources that span 

tribal, local, state, federal and international jurisdictions.

During the MPR process, improving collaborative and coordinated sanctuary management 

repeatedly emerged as one of the highest priorities for OCNMS to address over the next five to 

ten years. Ongoing regional efforts such as the Washington Ocean Action Plan and the West 

Coast Governor‟s Agreement on Ocean Health also have a strong focus on improving 

collaboration and coordination in order to address the complexity and enormity of current ocean 

management issues. 

Strategy CCM1: EXTERNAL EVALUATION

Evaluate the contribution of OCNMS‟ institutional relationships to the management of resources 

within OCNMS. 

Activity A: Bring in an independent organization to conduct an external evaluation of 

OCNMS‟ institutional relationships in order to obtain fresh insights, and to assess and 

support programmatic improvements in management of resources in the sanctuary.

Activity B: Report to the IPC and AC on the findings of the evaluation, and seek 

advice on potential improvements.
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FINAL MANAGEMENT PLAN

Figure 2 Diagram showing jurisdictional boundaries within OCNMS.

Strategy CCM2: COASTAL TREATY TRIBES

Consult with the Coastal Treaty Tribes (Makah, Quileute and Hoh Tribes and Quinault Indian 

Nation) in accordance with Executive Order 13175, and partner with tribal staff members to 

address sanctuary projects and management issues that are of interest to the tribes.

Activity A: Consult early and often with the Coastal Treaty Tribes on any changes to 

OCNMS regulations that could affect the tribes.

Activity B: Ensure individual tribes are kept informed about sanctuary projects, permit 

applications and management issues of interest.

Activity C: Work with individual Coastal Treaty Tribes to develop more specific, 

individually-defined tribal consultation procedures beyond those outlined in section 2.4.

Strategy CCM3: OLYMPIC COAST INTERGOVERNMENTAL POLICY COUNCIL

Continue OCNMS‟ partnership with the IPC.
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FINAL MANAGEMENT PLAN

Activity A: Implement the ONMS-IPC Memorandum of Agreement (MOA) by supporting 

quarterly IPC meetings, including an annual meeting with the ONMS Director and OCNMS 

staff.

Activity B: The Sanctuary Superintendent will brief the IPC annually on the previous year‟s 

progress in implementing the OCNMS management plan and on proposed annual operating 

plan activities for the coming year.

Activity C: In 2012, the respective parties will review and update the ONMS-IPC MOA with 

the intent to initiate another five-year term. 

Activity D: Collaborate with the IPC to develop a long-term research and monitoring plan 

that focuses on issue of mutual interest. 

Strategy CCM4: WASHINGTON STATE

Support implementation of the Washington Ocean Action Plan (OAP), the West Coast 

Governor‟s Agreement on Ocean Health, and other applicable state initiatives.

Activity A: Provide staff support and other resources to support Washington Ocean Caucus 

efforts on the Olympic Peninsula.

Activity B: Meet at least once a year with the Washington state Ocean Caucus and OCNMS 

Advisory Council state representatives to discuss implementation of the OAP and OCNMS

management plan. Identify how OCNMS research and conservation efforts can complement 

OAP implementation efforts.

Strategy CCM5: DEPARTMENT OF THE INTERIOR 

Enhance partnerships with Department of the Interior agencies, particularly the National Park 

Service (NPS) which manages Olympic National Park (ONP), and the U.S. Fish and Wildlife 

Service (USFWS) which manages the Washington Maritime National Wildlife Refuge Complex

(WMNWR). 

Activity A: Meet with NPS and USFWS leadership no less than twice a year.

Activity B: On an annual basis review areas of existing and potential future collaboration.

Strategy CCM6: UNITED STATES COAST GUARD

Coordinate with the U.S. Coast Guard (USCG) on the protection and management of the 

Nation‟s coastal waters and marine resources within OCNMS.

Activity A: Meet annually with the USCG to discuss collaborative efforts undertaken as part 

of this strategy; jointly prepare an Annual Report on the previous year‟s activities; and 

prepare a work plan for the coming year.

Activity B: Work with the USCG to develop an orientation plan for USCG personnel on 

joint USCG and OCNMS issues and regulations.

Activity C: Review and update the OCNMS/USCG Memorandum of Agreement 

(MOA-2002-117) prior to its expiration date (September 30, 2012).
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Strategy CCM7: UNITED STATES NAVY

Improve collaboration and coordination with the U.S. Navy. 

Activity A: Coordinate with other NOAA agencies in providing NOAA comments on Navy 

environmental compliance documents.

Activity B: Periodically meet with the Navy to identify ways to share, combine and 

maximize resources to conduct mutually beneficial research activities (e.g., habitat mapping)

and to identify additional sources of data that support OCNMS management (e.g., 

bathymetric data).

Activity C: Collaborate with the Navy to establish a mechanism through which the Navy and 

NOAA can work together on an ongoing basis to ensure Navy activities within OCNMS 

continue to be conducted in a manner that avoids to the maximum extent practicable any 

adverse impacts on resources in the sanctuary.

Strategy CCM8: NATIONAL MARINE FISHERIES SERVICE (NMFS)

Enhance ONMS‟ partnership with NMFS. 

Activity A: Meet annually with NMFS Northwest Region and Northwest Fisheries Science 

Center leadership.

Activity B: Work with NMFS to ensure the Pacific Fishery Management Council is 

informed about relevant projects, events and issues in the sanctuary and vice-versa.

Activity C: Coordinate with NMFS on issues of common interest within OCNMS 

boundaries, particularly ecosystem and habitat related research, policy and management 

actions.

Activity D: On an annual basis, document areas of existing and potential future 

collaboration.

Strategy CCM9: OFFICE OF NATIONAL MARINE SANCTUARIES

OCNMS staff will fully participate as a member of the Office of National Marine Sanctuaries 

(ONMS).

Activity A: Participate in annual national and regional leadership and programmatic 

meetings.

Activity B: Respond to agency requests for data and information.

Activity C: Locally implement national and regional initiatives.

Activity D: Provide subject matter expertise to regional, national and international initiatives 

as appropriate.

Activity E: Request and apply national and regional subject matter expertise to OCNMS 

issues. 
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FINAL MANAGEMENT PLAN

Strategy CCM10: CANADIAN GOVERNMENT

Work with Canadian government agencies to address transboundary issues. 

Activity A: Work with US and Canadian agencies, Coastal Treaty Tribes and First Nations, 

and conservation organizations to identify opportunities for advancing ecosystem-wide 

protection, research, education and outreach programs initiatives within the Juan de Fuca 

Eddy International Marine Ecosystem.

Activity B: Work with Parks Canada and British Columbia Parks to evaluate options for 

improving transboundary coordination and cooperation on shared objectives with adjoining 

Canadian marine protected areas (Pacific Rim National Park Preserve and Race Rocks 

Ecological Reserve/Marine Protected Area), including potential designation as a sister 

sanctuary through the ONMS International Program.

Activity C: Work with Fisheries and Oceans Canada on maritime safety and oil spill 

response issues through the Canada/U.S. Cooperative Vessel Traffic Service and the Pacific 

States/British Columbia Oil Spill Task Force.

Links to Other Action Plans: Community Involvement in Sanctuary Management, Sanctuary 

Operations, Habitat Mapping and Characterization, Physical and Chemical Oceanography, 

Populations, Communities and Ecosystems, Data Management, Sharing and Reporting, K-12 

Education, Higher Education, Visitor Services, Community Outreach, Spills Preparedness, 

Prevention, Response and Restoration, Climate Change, Marine Debris, Wildlife Disturbance, 

Water Quality Protection, Habitat Protection, Regional Ocean Planning, Maritime Heritage, 

Socioeconomic Values of Resources in the Sanctuary

Key Partners: Parks Canada, British Columbia Parks, Fisheries and Oceans Canada, Big Eddy 

International Marine Ecosystem Initiative and member organizations, Hoh, Makah and Quileute 

tribes, Quinault Indian Nation, Northwest Indian Fisheries Commission, Washington 

Departments of Natural Resources Fish and Wildlife, and Ecology, Washington Governor‟s 

Office, Washington Ocean Caucus, Olympic National Park, Washington Maritime National 

Wildlife Refuge Complex, U. S. Coast Guard, U.S. Navy, NMFS-Northwest Region, Northwest 

Fisheries Science Center, Pacific Fishery Management Council, NOAA Office of National 

Marine Sanctuaries (ONMS) and the ONMS West Coast Regional Office
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FINAL MANAGEMENT PLAN

A2. Community Involvement in Sanctuary Management Action Plan

Desired Outcome: Increased involvement of Olympic Peninsula communities in sanctuary 

management issues and ocean conservation.

Links to Goals:

Goal B - Promote collaborative and coordinated management and stewardship of resources in the 

sanctuary.

Background:

In addition to strengthening its relationships with agencies and governments with jurisdictional 

authority over resources in the sanctuary, OCNMS also recognizes the importance of improving 

1) its partnerships with local communities and non-governmental organizations and 2) the 

involvement of these groups (and individual citizens) in the sanctuary management process. 

As with the Collaborative and Coordinated Sanctuary Management Action Plan, this action 

plan focuses on building relationships and improving the sanctuary management process. 

Descriptions of specific, project-level partnerships with community groups (e.g., beach clean-up 

activities) appear in the appropriate, topical action plans (i.e., Marine Debris Action Plan).

OCNMS is mandated by the NMSA (Section 301(b)(7)) to involve communities and local 

organizations in the MPR process. The NMSA also mandates OCNMS involve local 

communities and groups in its Advisory Council (AC). Currently, the local county governments 

have a shared seat on the OCNMS AC, which also includes a citizen-at-large seat. Additionally, 

several other AC seats are currently filled by local community members who have expertise in 

particular fields such as education, tourism, commercial fishing and conservation. 

During the public scoping phase of the MPR process, it became clear:

 OCNMS should work to improve local communities‟ awareness of the sanctuary.

 OCNMS should work to improve public involvement in the AC.

 OCNMS should work to involve local communities in developing and shaping OCNMS 

education, research and stewardship programs.

 OCNMS programs would benefit from more overall success if local communities were 

more actively involved in implementing these programs.

Community involvement is increasingly recognized as crucial to achieving effective marine 

resource protection, which is the primary goal of the National Marine Sanctuaries Act. The 

state of Washington‟s recent initiative to empower and fund local counties to form Marine 

Resources Committees (MRCs) on Washington‟s outer coast underscores the importance of 

community-level involvement in ocean stewardship and conservation. MRCs are citizen-based 

organizations, the goal of which is to, “understand, steward, and restore the marine and estuarine 

ecological processes of the Washington coast in support of ecosystem health, sustainable marine 

resource-based livelihoods, cultural integrity, and coastal communities.” Other statewide and 

regional ocean conservation and management initiatives, including the West Coast Governor‟s 

Agreement on Ocean Health, the Washington Ocean Action Plan and the recently-passed 

state marine spatial planning bill, also emphasize active community involvement in ocean 

management decision-making processes. This action plan seeks to support these statewide and 
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FINAL MANAGEMENT PLAN

regional efforts and improve the sanctuary management process through more effective 

community partnerships and involvement. In addition to the strategies listed in this section, 

OCNMS work under Action Plan C, Improve Ocean Literacy, also directly benefits OCNMS 

community relations and strengthens community involvement in OCNMS activities.

Strategy COM1: ADVISORY COUNCIL

Involve local communities in sanctuary management issues through the AC process. 

Activity A: Fill all AC seats (both voting and non-voting) and encourage improved AC 

member attendance.

Activity B: Encourage stronger connections between AC members and local communities by 

increasing AC outreach efforts.

 Encourage AC members to post links to their organizations‟ on-line calendars on the 

OCNMS website.

 Encourage every AC member to forward AC meeting announcements to their 

organization‟s distribution list.

 Encourage AC members to include articles explaining the value of their involvement 

in the AC in their organizations‟ outreach publications.

 Work with AC members and OCNMS to host and attend social events in local 

communities on the outer coast (e.g., an annual open house). 

Activity C: Actively involve the AC in implementing the management plan.

 Identify strategies in the management plan that particular AC members, due to their

skills and interests, could help OCNMS implement. Put these AC members in 

contact with the staff in charge of these strategies.

 Solicit the AC‟s assistance in implementing management plan strategies through the 

establishment of standing subcommittees or working groups, as appropriate under the 

AC charter.

 Annually report to the AC on management plan implementation, including status of 

performance measures.

 Encourage the AC to provide advice on the success of management plan 

implementation efforts.

Strategy COM2: MARINE RESOURCES COMMITTEES

Continue and expand collaborative marine stewardship efforts with Clallam, Jefferson and Grays 

Harbor counties.

Activity A: Participate in the North Pacific Coast Marine Resources Committee.

Activity B: Participate in the Grays Harbor Marine Resources Committee.

Strategy COM3: NON-GOVERNMENTAL ORGANIZATIONS

Continue and increase, to the extent practicable, collaborative efforts with non-governmental 

organizations on the Olympic Coast.
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Activity A: Continue participation in/sponsorship of the Washington Clean Coast Alliance 

and the Coastal Observation and Seabird Survey Team (COASST).

Activity B: Maintain and develop partnerships with environmental NGOs such as Surfrider, 

The Nature Conservancy, Oceana, the Marine Biology Conservation Institute, Ecotrust and 

others in order to build support for marine conservation efforts in the sanctuary and the 

California Current ecosystem.

Activity C: Increase interactions and, if appropriate, develop partnerships with organizations 

representing commercial and recreational fishing industries and the shipping industry.

Links to Other Action Plans: Community Outreach, Marine Debris, Data Management, Sharing 

and Reporting, Climate Change, Habitat Protection, Regional Ocean Planning

Key Partners: Marine Conservation Institute, Surfrider Foundation, The Nature Conservancy, 

Oceana, Ecotrust, Olympic Coast Alliance, other NGOs, Westport Charterboat Association, 

Marine Exchange of Puget Sound, and other marine shipping and coastal fishing organizations, 

Olympic Coast National Marine Sanctuary Advisory Council and its members, North Pacific 

Coast and Grays Harbor marine resources committees, Clallam County, Jefferson County, Grays 

Harbor County
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FINAL MANAGEMENT PLAN

A3. Sanctuary Operations Action Plan

Desired Outcome: Improved efficiency and effectiveness in OCNMS management capacities 

and capabilities.

Links to Goals:

Goal H - Build, maintain, and enhance an operational capability and infrastructure. 

Background:

In order to effectively achieve the strategies outlined in the other 19 action plans, OCNMS needs 

to maintain basic staffing, infrastructure and administrative functions. This action plan addresses 

these operational needs and details OCNMS‟ plans to maintain its research vessel and on-water 

capabilities, maintain and train its staff and volunteers, maintain adequate facilities and other 

infrastructure, complete its annual budgeting process, manage contracts, maintain its regulatory 

program and report on management plan implementation progress. In effect, this Sanctuary 

Operations Action Plan supports all other action plans in the Final Management Plan.

Strategy OPS1: VESSEL INFRASTRUCTURE AND OPERATIONS

Maintain an on-water presence in the sanctuary to ensure effective and efficient sanctuary 

operations, including research and education activities.

Activity A: Develop annual operational plans for aircraft and vessels (NOAA, charter) to 

support the revised management plan.

Activity B: Maintain and implement operational guidelines and a vessel operator and crew 

member qualification plan.

Activity C: Implement field operations to address activities identified in the other action 

plans.

Strategy OPS2: FACILITIES 

Develop new and maintain current infrastructure for sanctuary offices, programs, research 

vessels, equipment, and field operations. 

Activity A: Provide office, field station, interpretive facilities, and warehouse facilities.

Activity B: Update and implement the OCNMS long-range facilities plan. Evaluate 

OCNMS‟ current office, lab and warehouse space and determine if changes need to be made 

to the plan to meet program needs identified during MPR.

 Evaluate current office spaces to determine if they meet future needs as articulated in 

the revised management plan.

 Evaluate the need to refurbish/replace OCNMS‟ Neah Bay field station.

 Evaluate the need for laboratory infrastructure.

 Evaluate OCNMS pier space needs.

 Evaluate the need for public meeting space and support infrastructure.

 Evaluate options for a satellite office on the Outer coast and/or a visitor center in the 

southern part of the sanctuary.
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FINAL MANAGEMENT PLAN

 Evaluate options for a joint visitor center in Port Angeles with the Feiro Marine Life 

Center and Olympic National Park.

 Explore opportunities to work with existing facilities on the outer coast, such as the 

University of Washington Olympic Natural Resources Center, in order to maintain an 

OCNMS staff presence on the outer coast.

Activity C: Develop the infrastructure to support and implement OCNMS‟ long-range 

interpretive plan.

Activity D: Implement OCNMS requirements of ONMS small boats requirements studies, as 

amended (including scheduled replacements of R/V Tatoosh and rigid hull inflatable boat).

Strategy OPS3: ANNUAL PLANNING

Prepare annual budgets, and develop and implement annual operating plans (AOPs) in support of 

management plan activities.

Activity A: Produce an annual operating plan and budget, per ONMS guidance and 

timelines.

Activity B: Oversee budget, contracts and acquisitions in compliance with Federal 

Acquisition Regulations.

Activity C: Submit required reports to ONMS headquarters.

Strategy OPS4: SAFE OPERATIONS

Maintain and, where appropriate, further develop procedures to ensure safe and responsible 

sanctuary operations.

Activity A: Develop, maintain and periodically test an OCNMS continuity of operations 

plan.

Activity B: Ensure compliance with NOAA directives, safety and workplace regulations, 

including those related to vessel safety. 

Activity C: Ensure compliance with NOAA directives and local, state and federal 

environmental compliance regulations.

Strategy OPS5: STAFFING

Recruit, retain and support staff in order to support ongoing programs and achieve the goals and 

objectives presented in the management plan.

Activity A: Support and maintain appropriate staffing to implement the OCNMS 

management plan.

Activity B: Contract for support services that cannot be filled by limited federal positions

and are needed to implement the OCNMS management plan.

Activity C: Improve training opportunities for staff, prioritizing training that will support

management plan implementation.
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Activity D: Conduct an internal evaluation of the OCNMS information technology (IT) plan 

on an annual basis and work to ensure IT services are adequate to support staff and program 

needs.

Strategy OPS6: VOLUNTEER PROGRAM

Maintain and enhance OCNMS‟ volunteer programs in order to build connections with the 

community and achieve the goals and objectives of the management plan.

Activity A: Actively recruit and train volunteers to promote community stewardship and to 

assist in the implementation of the OCNMS management plan.

Activity B: Improve training opportunities for volunteers, prioritizing training to support

management plan implementation.

Strategy OPS7: PERMITTING AND CONSULTATIONS

Implement the OCNMS permitting program based on OCNMS and national program regulations, 

guidance and performance measures; as well as other applicable laws, regulations and 

agreements.

Activity A: Review permit applications, conduct consultations with other agencies, 

governments and organizations, make permit decisions, develop appropriate documentation 

(may include permits, NEPA analysis, mitigation recommendations, and decision memos) 

and maintain records in the ONMS database.

Activity B: Brief the AC and IPC on major permit applications constituting new or major 

activities in the sanctuary.

Activity C: Report to the Coastal Treaty Tribes, AC and IPC annually on the status of permit 

applications and decisions to OCNMS and associated tribal consultations.

Activity D: Formally articulate the current tribal consultation process for permits. 

Activity E: Work with the state and other interested agencies and/or Coastal Treaty Tribes to 

develop a programmatic agreement on how OCNMS interprets and meets the requirements of 

Section 106 of the National Historic Preservation Act in the context of sanctuary historic 

resources.

Strategy OPS8: VOLUNTARY COMPLIANCE

Promote knowledge and understanding of OCNMS regulations, along with other regulations and 

voluntary programs that apply to sanctuary waters.

Activity A: Assess opportunities for educational signage about regulations at access points to 

the sanctuary (e.g., Neah Bay and La Push boat ramps).

Activity B: Develop interpretive materials to support enforcement efforts and promote public 

awareness of sanctuary regulations.

Activity C: Distribute a flyer on the Area to Be Avoided to the maritime industry through 

direct mail and by including in the Vessel Traffic Service Puget Sound Users Manual.

Activity D: Develop and distribute education materials on OCNMS‟ overflight regulation at 

air shows and other events.
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Strategy OPS9: ENFORCEMENT AND INCIDENT RESPONSE

Improve compliance with and enforcement of OCNMS regulations, other regulations, and 

voluntary programs that apply to sanctuary waters.

Activity A: Develop training opportunities for law enforcement professionals to promote and 

enhance their understanding of cultural and natural resources in the sanctuary and the 

regulations protecting them.

Activity B: Maintain bi-annual meetings with law enforcement staff (as described in the 

NMFS Office of Law Enforcement (OLE) 2009 report) and encourage increased presence of 

NOAA OLE and Washington Department of Fish and Wildlife (WDFW) law enforcement in 

the sanctuary.

Activity C: Work with NOAA OLE and the ONMS to clarify OCNMS enforcement needs as 

identified in 2010 ONMS/OLE 3-year Strategy for Clarifying Enforcement Needs and 

Testing Enforcement Measures.

Activity D: Promote active enforcement of the no-discharge regulation as it applies to 

abandoned vessels.

Activity E: Encourage vessel owners to carry insurance that would cover the salvage of their 

vessel if it sank in the sanctuary. Discuss sanctuary regulations and concerns with insurance 

companies to evaluate issues related to issuing insurance policies to cover salvaging of 

sunken vessels.

Activity F: Engage the USCG, at the earliest opportunity, to develop removal strategies for

vessel incidents that may result in vessel sinkings within sanctuary and to utilize the Oil Spill 

Liability Trust Fund (OSLTF) to prevent or mitigate oil pollution impacts.

Activity G: Work with NMFS, Pacific Fishery Management Council, Coastal Treaty Tribes 

and other partners to monitor compliance with Essential Fish Habitat regulations in the 

sanctuary.

Activity H: Clarify ambiguous or confusing aspects of the OCNMS regulations, and delete 

extraneous clauses. These changes to OCNMS regulations are being made as a rulemaking 

concurrently with the publication of the FMP. Regulatory changes include the following:

 Replace the term “seabed” with the term “submerged lands” throughout the 

regulations to match the language used in the OCNMS designation document;

 Replace the term “traditional fishing” with “lawful fishing” throughout the OCNMS 

regulations;

 Delete the out-dated OCNMS address and replace it with OCNMS‟ current address;

 Delete reference to leases/permits existing at the time of OCNMS designation (as 

none were found to exist);

 Delete the term “federal project” from the definitions and replace this reference in the 

regulations with a reference to the specific “Quillayute River Project”; and

 Clarify treaty trust responsibility language.

Activity I: Respond to emergency incidents in the sanctuary, as appropriate.
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Strategy OPS10: MANAGEMENT PLAN IMPLEMENTATION REPORTING

Establish reporting mechanisms/processes for management plan implementation and emerging 

issues.

Activity A: Report to partners and the public annually on the implementation of the 

management plan, particularly on performance measure achievement.

Activity B: Report to partners and the public annually on ONMS‟ response to emerging 

issues not anticipated in the management plan.

Activity C: Annually document any clarifications, lessons learned, enhancements or 

recommended changes to existing strategies and activities.

Activity D: Develop outreach materials to be used by OCNMS staff, AC and IPC members 

to convey information about management plan implementation to partners, stakeholders and 

constituent groups.

Activity E: Collaborate with regional natural resource management agencies to develop a 

response strategy or plan for unusual natural resource events (e.g., unexpected wildlife 

mortality events) not anticipated in the management plan.

Links to Other Action Plans: Collaborative and Coordinated Sanctuary Management, 

Community Involvement in Sanctuary Management, Habitat Mapping and Characterization, 

Physical and Chemical Oceanography, Populations, Communities and Ecosystems, Data 

Management, Sharing and Reporting, K-12 Education, Higher Education, Visitor Services, 

Community Outreach, Spills Preparedness, Prevention, Response and Restoration, Climate 

Change, Marine Debris, Wildlife Disturbance, Water Quality Protection, Habitat Protection, 

Regional Ocean Planning, Maritime Heritage, Socioeconomic Valuation of Resources in the 

Sanctuary

Key Partners: Advisory Council, Olympic Coast Intergovernmental Policy Council, West Coast 

sanctuaries, Makah, Quileute, Hoh Tribes and Quinault Indian Nation, Office of National Marine 

Sanctuaries, NOAA Safety and Environmental Compliance Office , NOAA Small Boat Program, 

NOAA Workforce Management Office, NOAA Acquisition and Grants Office, Feiro Marine 

Life Center, Makah Cultural and Research Center, Ocean Shores Visitor Center, Grays Harbor 

Historical Seaport Authority, COASST, State of Washington, ONP, FWS, ACOE, USCG, 

NOAA Office of Law Enforcement, Aircraft Owners and Pilots Association, Washington Pilots 

Association and others, Washington Department of Ecology, NMFS, Washington Department of 

Natural Resources, Washington Department of Fish and Wildlife, Washington Department of 

Archeology and Historic Preservation
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B. Conduct Collaborative Research, Assessments and Monitoring to 

Inform Ecosystem-Based Management

B1. Habitat Mapping and Classification Action Plan

B2. Physical and Chemical Oceanography Action Plan

B3. Populations, Communities and Ecosystems Action Plan

B4. Data Management, Sharing and Reporting Action Plan

Introduction

The OCNMS 2008 Condition Report, along with comments received during MPR scoping, 

emphasized the importance of data to inform management decisions and also identified 

significant data gaps related to our understanding of natural resources and ecosystem processes 

within the sanctuary. The intent of these four action plans is to outline a comprehensive research 

and monitoring program for OCNMS to undertake in partnership with other entities.

To maximize effectiveness of OCNMS‟ efforts, these action plans place a strong emphasis on 

maintaining and further developing collaborative scientific research and monitoring programs 

that address diverse aspects of habitat characterization, living resources monitoring and 

oceanographic and water quality monitoring. Additionally, a strong emphasis is placed on the 

need to improve data management, sharing and reporting. 

The action plans presented here are ambitious, and OCNMS‟ success in implementing them will 

in large part depend upon receipt of substantial grant funds (by OCNMS or its research partners). 

Activities that cannot be funded with the OCNMS budget alone are purposely included in the 

action plans because it is impossible to know how grant funding opportunities will change from 

year to year and what unforeseen funding sources might become available. OCNMS also hopes, 

in publishing a broad and comprehensive framework for research in the sanctuary, other 
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agencies, organizations and academic institutions might be encouraged to develop and fund 

research projects that OCNMS is unable to support.
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B1. Habitat Mapping and Classification Action Plan

Desired Outcome: Improved understanding of OCNMS habitats. 

Links to Goals:

Goal C - Investigate and enhance the understanding of ecosystem processes, and inform 

ecosystem-based management efforts, through scientific research, monitoring, and 

characterization. 

Background:

The mapping and classification of habitats and characterization of habitat-species associations 

provide critical information to support management, research, monitoring, and education within 

OCNMS, as well as within larger, regional ocean management regimes. Thus far, only 25% of 

the OCNMS seafloor has been adequately mapped, and only 19% has been characterized to 

habitat type. There is a clear need to complete seafloor surveys and characterize and identify 

species-habitat associations in order to inform management decisions.

Habitat mapping and characterization are high priorities for OCNMS, especially for recently 

discovered deep sea biogenic habitats that may be sensitive to anthropogenic disturbance. 

Mandates and needs for habitat mapping and characterization are highlighted in the NMSA, the 

West Coast Governor‟s Ocean Action Plan, the Washington State Seafloor Mapping Workshop, 

and for groundfish fishery management plans (which involve the Pacific Fishery Management 

Council, NMFS, Washington Department of Fish and Wildlife, Northwest Indian Fisheries 

Commission and Olympic Coast Intergovernmental Policy Council).

Strategy MAP1: REGIONAL COORDINATION

Develop and sustain partnerships to maximize and leverage seafloor and habitat mapping 

resources and to promote the use of established mapping standards. 

Activity A: Participate in regional forums to advance alignment and collaboration with 

broader mapping efforts, including initiatives of the Washington State Seafloor Mapping 

Committee and the West Coast Governors‟ Agreement on Ocean Health.

Activity B: Establish standards for the collection, assessment, verification, and application of 

seafloor mapping data in collaboration with regional forums. 

Activity C: Pursue opportunities to acquire and share existing seafloor and marine habitat 

data from federal, state, and local partners.

Strategy MAP2: SEAFLOOR HABITAT MAPPING 

Continue efforts to map seafloor habitats. 

Activity A: Conduct seafloor habitat mapping using the following considerations:

 Collect high quality, high-resolution sonar data in areas where no seafloor data exists

 Map contiguous areas

 Map hard substrate areas and other areas of probable or known important biogenic 

habitat
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 Map habitats with known or potential use by species of concern

 Map coastal areas less than 10 m water depth (i.e., areas most likely to be affected by 

oil spills)

 Utilize opportunities to collect partial sonar data types (e.g., sidescan only);

 Re-map areas where inadequate seafloor data exists

 Utilize opportunities to leverage ship time, equipment, and mobilization expenses

Activity B: Verify/ground truth sonar data through the collection and analysis of video, 

physical samples, or other methodologies. 

Strategy MAP3: HABITAT CLASSIFICATION

Integrate observations from sonar data and ground truthing to classify habitats and generate 

derivative maps and Geographic Information System (GIS) products. 

Activity A: Apply the classification scheme of Greene et al. (1999) and link this 

classification scheme with NOAA‟s Coastal and Marine Ecological Classification Structure. 

Activity B: Analyze data to generate derivatives of substrate data and geological features 

(e.g., seafloor morphology, slope, rugosity, stability/disturbance, tectonic features (faults) 

and submarine landslides). 

Activity C: Integrate habitat characterization information (as available) with biological, 

chemical, and ocean processes information to further understanding of habitat use. 

Strategy MAP4: MAPPING PRODUCTS

Report and share seafloor habitat characterization data in formats useful for resource managers 

and the public. 

Activity A: Develop digital mapping products that include fully interpreted, classified and 

attributed geologic and habitat maps. 

Activity B: Provide Federal Geographic Data Committee standard metadata for all maps and 

map products.

Activity C: Develop GIS products using ESRI software for export to open source GIS and 

Google Earth software, as well as other formats useful for public use and outreach. 

Activity D: Make mapping data available for integration and use in multiple applications, 

such as:

 Marine spatial planning

 Fisheries management

 Living marine resource management

 Assessing climate change and sea level change impacts

 Improving earthquake and tsunami hazard assessments

 Forecasting storm inundation and coastal erosion

 Siting of offshore infrastructure (e.g., aquaculture, renewable energy facilities)

Links to Other Action Plans: Collaborative and Coordinated Management, Marine Debris, 

Regional Ocean Planning, Habitat Protection
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Key Partners: NOAA (National Ocean Service and NMFS), U.S. Geological Service, USFWS, 

Washington Departments of Fish and Wildlife, Ecology, and Natural Resources, Makah, 

Quileute, and Hoh tribes, Quinault Indian Nation, Olympic Coast Intergovernmental Policy 

Council, Northwest Indian Fisheries Commission, Washington State Seafloor Mapping 

Consortium, West Coast Governors‟ Agreement on Ocean Health Seafloor Mapping Action 

Coordination Team, Washington Coast Sustainable Salmon Partnership, other NGOs, 

universities, international entities, U.S. Navy
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B2. Physical and Chemical Oceanography Action Plan

Desired Outcome: Improved understanding of overall water quality in the sanctuary 

Links to Goals:

Goal C - Investigate and enhance the understanding of ecosystem processes, and inform 

ecosystem-based management efforts, through scientific research, monitoring, and 

characterization. 

Background:

Near shore oceanographic conditions within OCNMS are poorly characterized with respect to 

temporal and spatial dynamics and ecological processes associated with changing conditions. 

Coastal ocean conditions off the Olympic Coast of Washington have a high degree of variability,

which complicates a thorough characterization of regional oceanographic processes and limits 

predictive abilities. This variability can span time scales from diel (day vs. night) through 

decadal (e.g., Pacific Decadal or El Niño Southern Oscillations) and spatial scales of micro- (1 to 

10 km) and meso- (10‟s to 100‟s of km). Such variability can have profound implications for the 

sanctuary‟s living resources. For example, strong El Niño years bring increased sea surface 

temperature and decreased primary productivity within the sanctuary.

Physical and chemical oceanographic data are useful to federal, tribal, university and statesponsored studies predicting harmful algal blooms, thereby helping assess potential threats to 

human health, shellfisheries, seabirds and marine mammals. These data are also used in the study 

of intertidal invertebrate and algae dynamics, in the ground truthing remote sensing data, in 

assisting with oil spill response and in improving our understanding of hypoxic conditions 

measured in near shore waters of Washington and Oregon. Additionally, expanded physical and 

chemical oceanographic monitoring programs are needed to address emerging concerns about 

ocean acidification.

OCNMS currently deploys (seasonally) anywhere from 10 to 13 monitoring buoys in the 

sanctuary‟s near shore environment to monitor water temperature, salinity, dissolved oxygen, 

currents and indicators of primary productivity. Additionally, OCNMS partners with and 

supports other agencies, organizations and academic institutions‟ efforts to conduct 

oceanographic monitoring in the sanctuary. OCNMS has supported University of Washington 

and Northwest Association of Networked Ocean Observing Systems (NANOOS) efforts to build 

and deploy a year-round, real-time oceanographic monitoring buoy and glider system off the 

coast of La Push and has frequently encouraged and supported efforts of researchers to conduct 

ocean acidification, harmful algal bloom, and oceanographic conditions research projects in the 

sanctuary. OCNMS also looks for opportunities to incorporate oceanographic monitoring, where 

appropriate and feasible, into sanctuary permit requirements. 

However, much more oceanographic information is needed in order to 1) understand the effects 

of a changing climate on sanctuary ecosystems and the large-scale ocean processes affecting

these ecosystems and 2) make informed sanctuary management decisions in response to a 

changing climate. Moreover, during the MPR process it became clear obtaining this 

oceanographic information is a priority for all statewide and regional ocean management entities 

and ocean researchers. The sanctuary is in a unique position to serve as both a laboratory and 
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classroom for conducting and sharing, respectively, oceanographic research. The aim of this 

action plan is to identify strategies OCNMS can undertake in order to foster regional 

oceanographic research efforts and build a stronger base of knowledge related oceanographic 

processes in the sanctuary. 

Strategy OCEO1: COASTAL MOORING PROGRAM 

Continue the OCNMS water quality monitoring program to monitor key physical and chemical 

oceanographic parameters in coastal waters. As feasible, expand this monitoring to include 

additional instrumentation (including acoustic monitoring), parameters, locations, year-round 

data collection, and real-time data transmission. 

Activity A: Monitor coastal waters using seasonally-deployed (spring through fall), 

instrumented moorings. 

 Continue use of established seasonal mooring locations.

 Collect data on temperature, salinity, dissolved oxygen, currents, chlorophyll.

 Calibrate instrumentation annually, or as necessary.

 Process data within one year and make available via a central, publically accessible 

web site.

Activity B: Consult with partners to determine research and resource management questions 

that can be addressed with existing or expanded water quality monitoring efforts. 

Activity C: Secure funding for additions and improvements to the OCNMS coastal water 

quality monitoring program. Program improvements could include: 

 Additional sensors or parameters

 Expanded spatial coverage

 Expanded seasonal coverage, potentially to year-round data collection 

 Real-time data transmission

Activity D: Support efforts to expand regional oceanographic monitoring programs (e.g., 

NANOOS, NDBC, UW), share data, model oceanographic processes, and improve public 

accessibility of this information. 

 Support the NANOOS coastal sensor array (2 buoys, 1 glider) at La Push.

 Participate as a partner in NANOOS meetings and conference calls.

 Promote NANOOS as a data resource for OCNMS partners and the public.

 Provide a link to NANOOS on the OCNMS website. 

Strategy OCEO2: HYPOXIA

Monitor dissolved oxygen levels and ecological impacts of hypoxic conditions (low oxygen 

concentration) in coastal waters. 

Activity A: Monitor, assess, and understand the spatial and temporal distribution of hypoxic 

conditions and their impacts on living organisms. 

Activity B: Expand monitoring to include additional locations, year-round data collection, 

and/or real-time data transmission, such as will be available with the La Push NANOOS 

buoy.
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Activity C: Promote collaborative efforts with the outer coast trustees and fishermen to 

collect field observations and conduct additional monitoring in response to identified hypoxic 

conditions. 

Strategy OCEO3: OCEAN ACIDIFICATION

Investigate changing ocean chemistry, acoustics and other physio-chemical changes and impacts 

to living organisms associated with increasing carbon dioxide levels in the atmosphere. 

Activity A: Collaborate in regional efforts to monitor and model carbonate system variables 

to improve understanding of the extent and severity of ocean acidification. 

Activity B: Collaborate in research on the effects of ocean acidification on calcifying and 

non-calcifying organisms, including deep sea corals, plankton, intertidal invertebrates, and on 

trophic relationships between these organisms.

Strategy OCEO4: HARMFUL ALGAL BLOOMS

Collaborate in regional efforts to research and monitor harmful algal blooms (HABs). 

Activity A: Work within the Olympic Region Harmful Algal Blooms (ORHAB) partnership 

and support efforts to monitor, detect, understand and predict HABs in the sanctuary region. 

Activity B: Use the timing of known HAB events as opportunities to encourage and conduct 

research and monitoring to characterize the initiation, dynamics and extent of impacts to 

natural resources and humans.

Links to other Action Plans: Climate Change, Populations, Communities and Ecosystems, 

Collaborative and Coordinated Sanctuary Management, Water Quality Protection

Key Partners: ORHAB, ECOHAB-PNW, NOAA (NOS, NWFSC, PMEL, NDBC, NCCOS), 

NANOOS, NASA, Makah, Quileute and Hoh Tribes, Quinault Indian Nation, Washington 

Departments of Ecology, Health, Fish and Wildlife, and Natural Resources, U.S. EPA, IPC, 

West Coast Governors‟ Agreement on Ocean Health Research Action Coordination Team,

University of Washington, Oregon State University/PISCO, Olympic National Park, other

universities, international entities, and NGOs
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B3. Populations, Communities and Ecosystems Action Plan

Desired Outcomes: 1) Improved understanding of health of and changes in sanctuary 

ecosystems; and 2) a more adaptive, ecosystem-based approach to research and management in 

the sanctuary.

Links to Goals:

Goal C - Investigate and enhance the understanding of ecosystem processes, and inform 

ecosystem-based management efforts, through scientific research, monitoring, and 

characterization. 

Background:

It is of significant interest to OCNMS, its Advisory Council and the IPC that data collected in the 

sanctuary be used to support adaptive and ecosystem-based management frameworks. Utilizing 

an ecosystem-based approach to ocean management is also a priority for NMFS, the Coastal 

Treaty Tribes and the state of Washington. For OCNMS and others to implement ecosystembased management in the sanctuary, information about biological and physical resources in the 

sanctuary must be collected across multiple scales. 

This action plan focuses primarily on biological resources and understanding the interactions 

between organisms and the physical environment. The action plan details research and 

monitoring priorities on an expanding scale including individual taxa, functional groups, 

populations, communities, and ecosystems. The goal of this action plan is to develop the body of 

scientific knowledge about the sanctuary in such a way ecosystem-based management decisions 

can be more effectively developed and substantiated. 

Strategy ECO1: WATER COLUMN COMMUNITIES

Conduct and collaborate in investigations of water column communities. 

Activity A: Monitor and encourage others to monitor pelagic larval phases of species of 

commercial and ecological significance (e.g., Dungeness crab, razor clams, mussels, 

euphausiids, copepods).

 Improve characterization of locations in water column, seasonal abundance and 

distribution of pelagic life phases of key marine species.

 Monitor pelagic zooplankton and forage fish abundance during on-water seabird and 

marine mammal surveys.

 Extend to year-round monitoring, as feasible.

Strategy ECO2: INTERTIDAL

Conduct and collaborate in research on the distribution and abundance of intertidal organisms.

Activity A: Coordinate with Olympic National Park (ONP) to evaluate the utility of 

continued monitoring of sand and rocky intertidal sites on Makah and Quinault reservations 

following ONP protocols. 

Activity B: Monitor rocky intertidal sites on Makah and Quinault reservations following the 

Multi-Agency Rocky Intertidal Network (MARINe) protocols. 
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 Incorporate data into the MARINe database. 

 Report the findings of intertidal monitoring efforts on an annual basis.

Activity C: Expand intertidal monitoring efforts, as feasible, to assess indicator species and 

parameters for particular stressors (e.g., climate change, competition, functional 

group/trophic coverage). 

Strategy ECO3: SUBTIDAL

Characterize the habitats and biota of the nearshore subtidal zone.

Activity A: Develop a Subtidal Monitoring Plan based on recommendations of Subtidal 

Workshop hosted by OCNMS in 2002. 

Activity B: Based on the Subtidal Monitoring Plan, implement subtidal habitat 

characterization and monitoring projects. 

Activity C: As indicator species and parameters for particular stressors (e.g., climate change, 

competition, functional group/trophic coverage) are identified, establish subtidal monitoring 

efforts. 

Strategy ECO4: BENTHIC

Investigate the abundance and distribution of benthic organisms, both epifauna and infauna, from 

subtidal to deeper shelf habitats.

Activity A: Collect data on abundance and distribution of benthic organisms, including during 

conduct of seafloor mapping, coral and sponge surveys, and benthic recovery studies. 

Activity B: Analyze and interpret data collected through video monitoring and other techniques 

and maintain a database for benthic organism distribution, abundance, and other quantifiable 

measures.

Activity C: Conduct surveys to identify distribution and abundance, characterize ecosystem 

values, and assess the condition of deep sea biogenic communities (e.g., corals and sponges). 

Activity D: As required in the Settlement Agreement between OCNMS and operators of the 

PC-1 submarine telecommunications cables, conduct benthic habitat monitoring on the PC-1 

cable routes to evaluate recovery of habitats following remediation of the cables conducted in 

2005. 

Strategy ECO5: FISH

Improve characterization of spatial and temporal distribution, abundance, and habitat use of fish.

Activity A: Collaborate with tribal, state, federal, and university researchers to assess the 

distribution, abundance, and productivity of forage fish populations, including documentation 

of intertidal areas used for spawning. 

Activity B: Solicit the AC‟s assistance, through establishment of an AC working group, in 

developing recommendations for pilot project(s) to investigate the abundance and 

distribution of fish.

Activity C: Continue partnership with Reef Environmental Education Foundation (REEF) 

for monitoring subtidal sites for fish and macroinvertebrate trends.
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Strategy ECO6: MARINE BIRDS

Improve characterization of spatial and temporal distribution, abundance, forage behavior and 

areas used by marine birds.

Activity A: Work with partners to evaluate past efforts for at-sea surveys and make 

recommendations for future surveys for temporal and spatial abundance and on-water 

distribution of marine birds. 

 Key partners include WDFW, NMFS, UW, and USFWS.

 Evaluation should include survey methodology (e.g., distance sampling), area 

coverage, data management and analysis, and reporting.

 Data gaps and information needs should be identified. Potential information needs 

include:

 Forage areas used throughout the year

 Migration periods

 Non-breeding seasons

 Parallel monitoring of pelagic zooplankton and forage fish abundance during 

on-water seabird surveys

 Conduct a power analysis of existing data to determine the minimum level of effort 

necessary to meet survey objectives (e.g., every 3-5 years vs. annual).

Activity B: Conduct at-sea monitoring of marine bird species following recommendations 

developed through evaluation of past survey efforts. 

Activity C: Provide in-field staff assistance to USFWS in monitoring abundance, 

productivity, and habitat use at coastal seabird colonies. 

Activity D: Continue to participate in Coastal Observation and Seabird Survey Team 

(COASST) as a regional coordinator of volunteers.

Activity E: Collaborate in update of the Catalog of Washington Seabird Breeding Colonies 

for colonies adjacent to and within OCNMS.

Activity F: Work with partners to establish a small number of coastal viewing sites to 

produce colony maps and periodic counts of nesting seabirds at easily-viewed coastal 

colonies.

Strategy ECO7: MARINE MAMMALS 

Improve characterization of spatial and temporal distribution, abundance, forage behavior and 

areas for marine mammals. 

Activity A: Provide in-field staff assistance to support the state of Washington‟s annual sea 

otter census.

Activity B: Collaborate in studies designed to detect the influence of sea otters on the 

distribution/abundance of prey species and any resulting changes in kelp habitat.

Activity C: Monitor temporal and spatial abundance and distribution of marine mammals, 

including identification of foraging areas used throughout the year. Collaborate in assessing

need for expanded efforts to assess migration and non-breeding time periods.
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Activity D: Monitor underwater acoustic environment and, as feasible, responses of marine 

mammals to acoustic disturbance.

Strategy ECO8: STRANDING NETWORKS

Participate in the regional marine mammal incident response networks. 

Activity A: Collaborate with other Northwest Marine Mammal Stranding Network 

(http://www.nwr.noaa.gov/Marine-Mammals/Stranding-Information.cfm) participants to 

share information and resources. Goals of the Network are to:

 Promote timely response and investigation of stranding events

 Minimize direct interactions between stranded marine mammals, humans and 

domestic animals

 Maximize collection of biological specimens for examination and other data

 Improve the detection of signs of human interactions that may have contributed to 

stranding events

Activity B: Participate in the regional sea otter stranding network. 

Strategy ECO9: ECOSYSTEM PROCESSES

Collaborate in ongoing efforts by the NOAA Northwest Fisheries Science Center and others to 

develop and apply a comprehensive ecosystem model that identifies indicator species, trophic 

networks, and physical-biological coupling. 

Activity A: Evaluate indicator species identified by and currently used by OCNMS and 

regional co-managers (i.e., routine monitoring, 2008 OCNMS Condition Report). 

 Base this evaluation on an established or tested framework for selection of indicator 

species for ecosystem status assessment.

 Consult with co-managers and ecosystem model experts.

 Consider trophic networks and physical-biological coupling.

 Incorporate traditional ecosystem knowledge, as appropriate.

 Develop a formal report to summarize this evaluation.

 Include recommendations for a revised set of indicator or sentinel species for which 

monitoring can be conducted or encouraged by OCNMS.

Activity B: Based on the revised set of indicator species (developed in Activity A), evaluate 

OCNMS‟ research and monitoring priorities, and recommend changes, if appropriate.

Activity C: Use defined indicators to evaluate ecosystem status and trends, and include this 

information in the next OCNMS Condition Report and provide it to ecosystem modelers. 

Activity D: Summarize the removal histories and biological metrics (length, weight, or age 

compositions) for indicator species.

Links to other Action Plans: Habitat Mapping and Classification, Physical and Chemical 

Oceanography, Data Management, Sharing and Reporting, Collaborative and Coordinated 

Sanctuary Management, Habitat Protection
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Key Partners: NOAA (NMFS, NOS, PMEL, NWFSC), USFWS, ONP, USGS, USCG, MMS, 

U.S. Navy, OSU/PISCO, DFO, MARINe Washington Departments of Fish and Wildlife, 

Ecology, and Natural Resources, Olympic Coast Intergovernmental Policy Council, OCNMS 

Advisory Council, Makah, Quileute and Hoh tribes, Quinault Indian Nation, Northwest Marine 

Mammal Stranding Network, West Coast Governors‟ Agreement on Ocean Health Ecosystem 

Indicators Action Coordination Team, Washington State Ocean Caucus, Puget Sound 

Partnership, REEF, COASST, Grays Harbor and North Pacific Coast marine resources 

committees, NGOs, Juan de Fuca International Marine Conservation Initiative, universities and 

colleges, coastal communities, international entities
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B4. Data Management, Sharing and Reporting Action Plan

Desired Outcome: Improved awareness of the status of OCNMS resources and the sanctuary‟s 

overall ecological health.

Links to Goals:

Goal C - Investigate and enhance the understanding of ecosystem processes, and inform 

ecosystem-based management efforts, through scientific research, monitoring, and 

characterization. 

Background:

The importance of analyzing and sharing data collected by OCNMS in a timely manner has been 

emphasized throughout the MPR process. Because data management, sharing and reporting is a 

topic relevant to all research, assessment and monitoring strategies and activities, it was decided 

to consolidate a concise set of data management strategies into one action plan.

Processing, analyzing and reporting OCNMS data collection efforts in a timely manner, has been 

a real challenge for OCNMS staff in recent years, particularly given decreasing resources to 

support this work. Often times, OCNMS receives funding to conduct research projects, but not 

the funding to support data processing and analysis after the fact. OCNMS‟ ability to manage, 

share and report the data it collects directly affects its ability to support an ecosystem-based 

management framework and the ability of OCNMS partners to make informed management 

decisions. Thus, the goal of this action plan is to guide OCNMS in improving its data 

management, sharing and reporting efforts for the benefit of OCNMS and all its partners.

Strategy DAT1: DATA QUALITY CONTROL AND MANAGEMENT 

Develop and promote data management procedures. 

Activity A: Develop a data management plan outlining OCNMS‟ entire data management 

process. The data management plan should define quality control, data documentation, data 

collection, data processing, and data management (metadata) methods. 

Activity B: Encourage, and when OCNMS has authority ensure, the use of federal guidelines 

for data reporting (e.g., as promoted by the Biological and Chemical Oceanography Data 

Management Office) for research in the sanctuary. 

Strategy DAT2: DATA DISTRIBUTION

Provide easy and timely access to data collected or managed by OCNMS.

Activity A: For data collected and managed by OCNMS, ensure timely and wide distribution 

of data, as data management procedures allow. 

 Focus on releasing data collected in the past.

 Make new data available in a timely manner (i.e., as it is processed).

 Provide annual summaries of OCNMS data products.

Activity B: Encourage access to data, data derivatives, and data summaries through widelyused and appropriate web-based data portals. 
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 Collaborate with partners who collect data in the sanctuary to identify common 

databases, data fields, etc. and to develop standardized databases to facilitate data 

retrieval, when feasible or practical

 Participate in West Coast Observing System efforts related to metadata development

 Upload data to the NOAA Coastal Data Development Center (NCDDC) web site for 

public access

Activity C: Provide links on the OCNMS web site to data portals that host OCNMS data and 

notify regional natural resource managers of these portals. 

Activity D: Provide data managed by OCNMS to collaborators for their reports and 

summaries, and assist collaborators with the development of reporting products.

Strategy DAT3: ADAPTIVE MANAGEMENT

Periodically evaluate data collection efforts by OCNMS to ensure that data are useful to OCNMS 

and other marine resource managers and that data needs are clear to staff and other researchers. 

Activity A: Solicit the AC‟s and IPC‟s assistance in developing recommendations for 

periodically assessing and updating OCNMS research activities and priorities based upon 

evolving scientific information and management needs, through the establishment of an AC 

working group or other available means. 

Activity B: Continue to periodically hold workshops or other similar forums to engage 

researchers (academic and otherwise) in discussions of methodologies and research questions 

best suited to meet the needs of OCNMS and other regional marine resource managers.

Strategy DAT4: CONDITION REPORT

Publish a Condition Report on the sanctuary at a regular frequency, at a minimum prior to the 

next management plan review process.

Links to other Action Plans: Collaborative and Coordinated Sanctuary Management, Habitat 

Mapping and Classification, Physical and Chemical Oceanography, Populations, Communities 

and Ecosystems, Climate Change, Regional Ocean Planning

Key Partners: NOAA (NMFS, NOS), USFWS, USGS, ONP, Washington Departments of Fish 

and Wildlife, Ecology, and Natural Resources, IPC, Makah, Quileute and Hoh tribes, Quinault 

Indian Nation, NANOOS, USFWS, Washington State Seafloor Mapping Consortium, OCNMS 

Advisory Council, NGOs, universities and colleges
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C. Improve Ocean Literacy

C1. K-12 Education Action Plan

C2. Higher Education Action Plan

C3. Visitor Services Action Plan

C4. Community Outreach Action Plan

Introduction

Enhancing the public‟s awareness and appreciation of natural and cultural resources is a 

cornerstone of OCNMS‟ mission, which follows directly from mandates of the NMSA. Over the 

next five to ten years, OCNMS, in partnership with the Coastal Treaty Tribes, non-tribal coastal 

communities, National Park Service, Seattle Aquarium, Feiro Marine Life Center, Ocean Shores 

Interpretive Center, E3 Washington, and others, proposes to continue and expand existing – and 

develop new – education and outreach programs around the concept of Ocean Literacy.

Ocean Literacy, broadly defined, is an enduring understanding of the ocean‟s influence on 

people and people‟s influence on the ocean in a manner encouraging lifelong attitudes of ocean 

resource stewardship and personal commitment. In addition to conveying information about the 

sanctuary‟s marine organisms, habitats and ecosystems, OCNMS‟ Ocean Literacy program will 

work collaboratively to convey information about:

 Tribal culture and traditions, as well as treaty making and implementation

 Climate change and ocean acidification

 Cultural uses and socioeconomic values of sanctuary resources

 Ocean management and policy frameworks, such as ecosystem-based management

 Ocean stewardship 
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Each action plan in this grouping addresses a different sector of the public served by OCNMS 

programs: K-12 students, post-secondary students, local communities and visitors (including the 

general public outside the sanctuary region).
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C1. K-12 Education Action Plan

Desired Outcomes: 1) Improved understanding by teachers and students of Ocean Literacy 

principles and the ocean‟s importance; and 2) K-12 students in the sanctuary region are better

prepared to enter careers that require an understanding of Ocean Literacy.

Links to Goals:

Goal D - Enhance Ocean Literacy, promote awareness of the sanctuary and foster a sense of 

ocean stewardship through outreach, education, and interpretation efforts. 

Background:

Engaging K-12 students and teachers in experiential education programs focused on the Olympic 

Coast marine environment is key to improving Ocean Literacy and fostering a lifelong respect 

for and understanding of the Olympic Coast and ocean ecosystems in general. The outer coast of 

the Olympic Peninsula is a remote and economically depressed region and the K-12 schools in 

the area do not have access to the resources necessary to provide students with hands-on marine 

science education. 

OCNMS is one of a very few organizations on the Olympic Peninsula with staff expertise in both 

marine science and environmental education and thus it is crucial that OCNMS maintain and 

build upon its K-12 Ocean Literacy programs. OCNMS‟ collaborative K-12 Ocean Literacy 

programs have been incredibly successful and OCNMS receives more requests for programs than 

can be accommodated. Local schools are depending upon OCNMS to provide marine science 

and education programs, and OCNMS has both a strong obligation and interest in providing local 

students with hands-on opportunities to learn about the sanctuary. 

Strategy ED1: K-12 PARTNERSHIPS

Work in partnership with regional education organizations in order to leverage resources for 

K-12 Ocean Literacy programs.

Activity A: Collaborate with partners, including recipients of NOAA funding (e.g., B-WET 

grants), to maximize the effectiveness of NOAA resources and promote the NOAA Strategic 

Education Plan.

Activity B: Promote education opportunities that bring NOAA science and education 

resources to educators and students in the region. These opportunities include, but are not 

limited to: Teacher At Sea, Get to Know NOAA, various data visualization products, and 

distance learning.

Activity C: Work directly with classroom teachers to integrate OCNMS and other Ocean 

Literacy programs into existing school curricula.

Activity D: Promote the Ocean Literacy goals and strategies in the West Coast Governors‟ 

Agreement on Ocean Health (which include incorporating Ocean Literacy into Washington 

State Learning Goals Standards).
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Strategy ED2: PLACE-BASED EDUCATION 

Work collaboratively with rural schools and tribal communities adjacent to the sanctuary and 

within the sanctuary region to develop place-based education opportunities for K-12 students. 

Activity A: Work with school districts, tribal partners, home-school organizations in local 

communities, non-profit and other education organizations to design and implement program 

curricula to 1) meet education standards, 2) fulfill needs identified by regional educators and, 

3) emphasize place-based and hands-on learning.

Activity B: Work with local area high schools to develop senior culminating projects that 

involve students in OCNMS programs, and engage the Pacific Education Institute in training 

OCNMS staff to be student mentors.

Activity C: Collaborate with local schools to develop student citizen science projects in and 

adjacent to the sanctuary (e.g. beach clean-ups).

Activity D: Develop summer youth programs and/or curricula to support summer youth 

programs.

Strategy ED3: REGIONAL INITIATIVES

Participate actively in relevant regional education organizations and initiatives.

Activity A: To the greatest extent feasible, participate in meetings, conferences and projects 

of the Pacific Education Institute, E3 Washington, the Northwest Aquatic and Marine 

Educators, the Environmental Education Association of Washington and the Washington 

Science Teachers Association.

Activity B: Work to promote regional environmental education initiatives in the sanctuary 

region (e.g., “no child left inside”).

Strategy ED4: TECHNOLOGY

Employ current and emerging technologies in order to make Ocean Literacy information and 

curricula more accessible and provide students with a richer educational experience. 

Activity A: Enhance OCNMS website to be a source of Ocean Literacy information such as 

NOAA-authored educational/curriculum materials and news articles on ocean issues.

Activity B: Develop the capacity for high-quality video conferencing to enhance 

collaboration with partners and deliver education programming to geographically remote 

audiences.

Activity C: Work cooperatively with other sanctuaries, the Office of National Marine 

Sanctuaries and the National Estuarine Research Reserves to bring into classrooms live, 

interactive educational programs that utilize telepresence.

Links to Other Action Plans: Collaborative and Coordinated Sanctuary Management, Climate 

Change, Marine Debris, Wildlife Disturbance, Higher Education

Key Partners: Makah, Quileute and Hoh Tribes and the Quinault Indian Nation, Olympic Coast 

Intergovernmental Policy Council, Seattle Aquarium, Olympic Park Institute, Olympic National 

Park, North Pacific Coast and Grays Harbor marine resources committees, Feiro Marine Life 
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Center, Port Townsend Marine Science Center, Port Angeles School District, Quillayute Valley 

School District, North Beach School District, Cape Flattery School District, Sequim School 

District, Quileute Tribal School, local home school organizations, University of Washington 

Olympic Natural Resources Center, West Coast Governors‟ Agreement on Ocean Health Ocean 

Awareness and Literacy Action Coordination Team, Washington State Ocean Caucus, 

Washington Sea Grant, North Olympic Skills Center, the Pacific Education Institute, Grays 

Harbor Historical Seaport Authority, Northwest Aquatic and Marine Educators, Environmental 

Education Association of Washington, Washington Science Teachers Association, Makah 

Cultural and Research Center, National Park Service Research Learning Centers, Office of 

National Marine Sanctuaries, other sanctuaries
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C2. Higher Education Action Plan

Desired Outcomes: 1) OCNMS becomes a catalyst for higher education opportunities in marine 

fields; and 2) post-secondary students in the sanctuary region have greater access to careerbuilding opportunities in ocean research, education, policy and management

Links to Goals: 

Goal D - Enhance Ocean Literacy, promote awareness of the sanctuary and foster a sense of 

ocean stewardship through outreach, education, and interpretation efforts. 

Background:

Coastal rural and American Indian communities face a paradoxical challenge: they depend 

increasingly on science-based natural resource management in order to sustain resources and 

economies, yet lack of educational funding, opportunities, expertise and conflicting social 

problems create overwhelming educational challenges. Opportunities to learn basic and applied 

science and job skills in these communities are limited, and pathways to careers and success are 

not evident. In addition, connections between vocational, college and graduate students, and 

working experts are poorly defined. 

OCNMS is in a unique position to show leadership in the region in promoting career-building 

opportunities in marine sciences, education, management and policy. The aim of this action plan 

is to identify ways in which OCNMS can collaborate with universities, colleges and community 

colleges to improve higher educational opportunities for students and encourage students to 

pursue ocean and marine-related fields.

Strategy HED1: INTERNSHIP DEVELOPMENT

Coordinate internship activities between local colleges, universities, community colleges and 

OCNMS to create learning opportunities within the areas of sanctuary operations, research, 

education and management. 

Activity A: Formalize an OCNMS internship coordinator staff role.

Activity B: Develop appropriate guidelines for academic elements of OCNMS internships.

Activity C: Establish an OCNMS summer internship program for undergraduates and 

Running Start students (http://www.k12.wa.us/runningstart/default.aspx) and advertise this 

program locally.

Strategy HED2: VOLUNTEER POSITIONS

Develop the necessary agreements and advertising instruments to recruit and utilize AmeriCorps

and/or Student Conservation Association volunteer positions at OCNMS.

Strategy HED3: COLLEGE PARTNERSHIPS

Build partnerships with regional colleges, universities, foundations and other institutions in order 

to increase educational opportunities in ocean science, education, policy and management fields. 

Activity A: Participate in local career days and job fairs.
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Activity B: Develop opportunities with local colleges to provide OCNMS staff and other 

experts as lecturers, presenters and/or adjunct faculty.

Activity C: Develop continuing education programs on ocean issues and explore 

opportunities for developing consortia between local colleges, Coastal Treaty Tribes, 

agencies and non-profits.

Activity D: Develop opportunities for students to be involved in marine research – in person 

or via high-quality video conferencing with research vessels or stations.

Activity E: Provide continuing education opportunities for teachers to receive academic 

credit and gain experience in order to enhance their understanding of marine science content 

areas and methods for hands-on science education.

Activity F: Work collaboratively with foundations, local colleges and universities, tribal 

communities and other agencies to develop college scholarship funds for students from the 

Coastal Treaty Tribes who are interested in pursuing college degrees in marine policy, 

science, conservation, education and other related fields. 

Links to Other Action Plans: Collaborative and Coordinated Sanctuary Management, 

Community Involvement in Sanctuary Management, Sanctuary Operations, Climate Change

Key Partners: Peninsula College, WWU Huxley Program on the Peninsula, Grays Harbor 

College, the University of Washington Olympic Natural Resources Center , North Olympic 

Skills Center, Olympic National Park, Olympic Park Institute, North Pacific Marine Resources 

Committee, Grays Harbor Marine Resources Committee, Makah, Quileute and Hoh Tribes and 

the Quinault Indian Nation, Olympic Coast Intergovernmental Policy Council, Seattle Aquarium, 

Olympic Park Institute, Feiro Marine Life Center, West Coast Governors‟ Agreement on Ocean 

Health Ocean Awareness and Literacy Action Coordination Team , Washington Sea Grant, 

Office of National Marine Sanctuaries, AmeriCorps, American Indian College Fund (and other 

foundations), Makah Cultural and Research Center, National Park Service Research Learning 

Centers, Office of National Marine Sanctuaries, Seattle Aquarium, other sanctuaries
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C3. Visitor Services Action Plan

Desired Outcomes: 1) Improved awareness of OCNMS; 2) increased visitor awareness of ocean 

issues; and 3) an enriched and extended coastal travel experience.

Links to Goals: 

Goal D - Enhance Ocean Literacy, promote awareness of the sanctuary and foster a sense of 

ocean stewardship through outreach, education, and interpretation efforts. 

Goal G - Facilitate wise and sustainable use in the sanctuary to the extent that such uses are 

compatible with resource protection.

Background:

Improving the general public‟s awareness of OCNMS, providing planning assistance and 

information to Olympic Coast visitors, providing high-quality educational experiences to 

visitors, encouraging visitors to the sanctuary to become better ocean stewards, and working with 

local communities to encourage sustainable tourism in the sanctuary region are all important 

aspects of OCNMS‟ visitor services program. 

OCNMS‟ current visitor services program is relatively small and the public scoping process 

made it clear, the public would like to see a more robust OCNMS visitor services program. In 

recent years, funding for OCNMS visitor services activities has been drastically reduced. Thus, 

the goal of this action plan is to outline a series of strategies to guide development of OCNMS‟

visitor services program as resources become available. The action plan focuses on both using 

new technology (social networking, podcasts, interactive website tools, etc.) to disseminate 

information about OCNMS to a wider audience and working with partners to leverage limited 

resources.

Strategy VISIT1: VISITOR EXPERIENCE

Actively collaborate with other agencies, tribal governments, tourism organizations and the 

private sector to provide services and products that contribute to high-quality educational 

experiences for visitors to the Olympic Peninsula.

Activity A: Develop education and outreach materials, in a variety of media, to attract 

visitors, orient them to the region‟s amenities, educate them on resources in the sanctuary and 

inspire a sense of stewardship for the environment.

Activity B: Participate in regional forums and planning processes that contribute to a strong 

tourism economy for the Olympic Peninsula.

Activity C: Offer technical assistance and training to partners and businesses that serve and 

educate visitors.

Activity D: Provide funding, training and support to cooperative interpretation programs 

with OCNMS partners.

Activity E: Expand efforts to develop interpretation programs on the Makah, Quileute, Hoh 

and Quinault Indian reservations as a way of developing program capacity, tourism 

enterprise, and training and job opportunities for tribal members.
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Strategy VISIT2: LONG-RANGE INTERPRETIVE PLAN

Develop and implement a Long-Range Interpretive Plan for OCNMS.

Activity A: Actively involve partners and stakeholders in Long-Range Interpretive Plan 

development.

Activity B: Work collaboratively to identify opportunities to develop additional visitor centers, 

wayside exhibits, informational signs, kiosks and aquarium/museum exhibits in the sanctuary 

region.

Activity C: Work collaboratively to ensure the Long-Range Interpretive Plan reflects the 

region‟s specific needs as they relate to visitor service infrastructure development.

Activity D: Coordinate with other sanctuaries in the West Coast Region also developing 

interpretive plans.

Activity E: Include in the Long-Range Interpretive Plan specific strategies to enhance 

effectiveness of the Olympic Coast Discovery Center (OCDC). These strategies should identify 

ways to: recruit, train and retain volunteers; coordinate and collaborate with the Feiro Marine 

Life Center and Olympic National Park as they develop a larger and more expansive coastal 

visitor and education center in Port Angeles; maintain and update existing exhibits; attract new 

visitors; and increase development and enrichment activities for staff and volunteers.

Strategy VISIT3: NEW TECHNOLOGY

Utilize current and emerging technologies in order to educate and inform physical and virtual 

visitors to the Olympic Coast.

Activity A: Complete an update and overhaul of the OCNMS website.

Activity B: Integrate other appropriate technologies, as feasible, into the website including social 

networking resources, smartphone applications, podcasts, webcasts of video etc.

Activity C: Update facilities, hardware and software to accommodate telepresence so visitors to 

sanctuary and partner facilities can be linked to research vessels, other education centers etc.

Links to Other Action Plans: Climate Change, Marine Debris, Wildlife Disturbance, Maritime 

Heritage, Collaborative and Coordinated Sanctuary Management

Key Partners: Makah, Quileute and Hoh Tribes and the Quinault Indian Nation, Olympic Coast 

Intergovernmental Policy Council, Makah Cultural and Research Center, Olympic National Park, Feiro 

Marine Life Center, Port Townsend Marine Science Center, Port Angeles School District, Ocean 

Shores Interpretive Center, Grays Harbor Historical Seaport Authority, OCDC volunteers, the 

communities of Port Angeles, Sequim, Neah Bay, La Push, Forks, Hoh River, Taholah, Ocean Shores, 

Westport and Pacific Beach, Makah Cultural and Research Center, Aramark/Kalaloch Lodge, West 

Coast Governors‟ Agreement on Ocean Health Ocean Awareness and Literacy Action Coordination 

Team, National Park Service Research Learning Centers, Office of National Marine Sanctuaries, 

Seattle Aquarium, other sanctuaries
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C4. Community Outreach Action Plan

Desired Outcomes: 1) Greater involvement of local communities in OCNMS programs and onthe-ground marine conservation efforts; and 2) a stronger connection between local communities 

and OCNMS.

Links to Goals: 

Goal D - Enhance Ocean Literacy, promote awareness of the sanctuary and foster a sense of 

ocean stewardship through outreach, education, and interpretation efforts. 

Goal H - Build, maintain, and enhance an operational capability and infrastructure. 

Background:

Effective community outreach is critical to the success of all OCNMS programs; and the need to 

improve OCNMS‟ relationships with local communities on the Olympic Peninsula has 

repeatedly emerged as a high priority during the MPR process. The Community Involvement in 

Sanctuary Management action plan, presented earlier in the FMP, addresses ways in which 

OCNMS can facilitate more community involvement in OCNMS management and decisionmaking. The Community Outreach action plan focuses more on involving local citizens in 

specific OCNMS volunteer programs and improving OCNMS staff presence on the outer coast

so that local communities develop a stronger connection with staff. While the Community 

Outreach action plan is housed within the “Improve Ocean Literacy” priority issue, the action 

plan has been written broadly so it supports action plans related to research, living resources 

conservation and other program areas.

Strategy OUT1: STEWARDSHIP AND CITIZEN SCIENCE

Actively support marine stewardship and citizen science volunteer programs.

Activity A: Provide training and staff support to OCNMS volunteers involved with the 

Coastal Observation and Seabird Survey Team, Washington CoastSavers, and other 

volunteer programs in the sanctuary.

Activity B: Support efforts of the North Pacific Coast and Grays Harbor marine resources 

committees to develop citizen science and marine stewardship efforts in the sanctuary. 

Activity C: Use traditional media and new technologies to advertise opportunities for 

community members to volunteer on OCNMS education and research projects.

Strategy OUT2: STAFF PRESENCE ON OUTER COAST

Assess needs and opportunities to develop a stronger OCNMS staff presence on the outer coast

of the Olympic Peninsula.

Activity A: Work with sanctuary partners who have existing facilities on the outer coast to 

explore office-sharing opportunities.

Activity B: Conduct feasibility and cost analyses of a “South Coast” satellite office in Grays 

Harbor County and a “West End” satellite office in Forks.

Activity C: Evaluate opportunities for “storefronts” and/or visitor information centers in 

coastal communities.
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Strategy OUT3: COMMUNITY EVENTS

Maintain an OCNMS staff presence at community events and meetings in the sanctuary region.

Activity A: Develop an annual outreach plan including priorities for community events, 

staffing and volunteers, as well as priority themes and messages.

Activity B: Attend (as invited) events, festivals and meetings in tribal and non-tribal 

communities in the sanctuary region. 

Activity C: Provide regular briefings to service clubs, local governments, chambers of 

commerce, tourism organizations, stakeholder groups and others on matters pertaining to the 

sanctuary.

Activity D: Furnish expert speakers for public lecture series, community meetings and other 

forums in order to provide up-to-date information on sanctuary research, education, policies 

and management activities.

Strategy OUT4: COMMUNITY-BASED EFFORTS

Actively support the efforts of the North Pacific and Grays Harbor marine resources committees, 

regional watershed councils, salmon recovery teams, the Puget Sound Partnership, other 

community-based NGOs, and local and state governments in areas of marine research, education, 

and policy coordination.

Activity A: Participate in relevant meetings of community-based organizations and 

initiatives in the sanctuary region.

Activity B: Jointly pursue opportunities for community-based marine education, stewardship 

and research programs.

Activity C: Use the OCNMS website, e-mail listserv and other media to communicate the 

efforts of community-based organizations working on ocean issues in the sanctuary region.

Links to Other Action Plans: Community Involvement in Sanctuary Management, Maritime 

Heritage, Populations, Communities and Ecosystems, Climate Change, Marine Debris, Regional 

Ocean Planning, Collaborative and Coordinated Sanctuary Management

Key Partners: COASST, Washington CoastSavers, Washington Clean Coast Alliance, Makah, 

Quileute and Hoh Tribes and the Quinault Indian Nation, Olympic Coast Intergovernmental 

Policy Council, Makah Cultural and Research Center, Feiro Marine Life Center, Port Townsend 

Marine Science Center, Olympic National Park, Grays Harbor and North Pacific Coast marine 

resources committees, Grays Harbor Historical Seaport Authority, National Coast Trail 

Association, Puget Sound Partnership, West Coast Governors‟ Agreement on Ocean Health 

Ocean Awareness and Literacy Action Coordination Team, Washington State Ocean Caucus, 

Washington Sea Grant, Clallam, Jefferson and Grays Harbor counties, state of Washington, local 

organizations such as Rotary and Lions Clubs, Surfrider Foundation chapters, local kayaking 

groups and others
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D. Conserve Natural Resources in the Sanctuary

D1. Spills Prevention, Preparedness, Response and Restoration Action Plan

D2. Climate Change Action Plan

D3. Marine Debris Action Plan

D4. Wildlife Disturbance Action Plan

D5. Water Quality Protection Action Plan

D6. Habitat Protection Action Plan

D7. Regional Ocean Planning Action Plan

Introduction

The primary mandate of the Office of National Marine Sanctuaries is to protect sanctuary 

resources. Therefore, it is OCNMS‟ responsibility to reduce threats to sanctuary resource

sustainability and condition. OCNMS also has a responsibility to facilitate compatible uses in 

the sanctuary in a manner that 1) is consistent with its treaty trust responsibilities, 2) promotes 

healthy and resilient natural resources, and 3) allows human uses to continue in a sustainable

way. The seven action plans presented here highlight the primary resource conservation 

concerns that emerged from the MPR scoping process and the Living Resources Conservation 

working group that was formed as part of the MPR process. In many cases, the action plans 

indicate further assessment of potential impacts to resources in the sanctuary is needed in order 

to determine if there is a need for additional management measures.
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D1. Spills Prevention, Preparedness, Response and Restoration Action Plan

Desired Outcomes: 1) Increased protection of marine, cultural, and shoreline resources from the 

impacts of an oil or hazardous materials spill; and 2) improved preparedness and coordination for 

responding to spills affecting marine resources within OCNMS.

Links to Goals: 

Goal A - Build and strengthen OCNMS‟ partnerships with the Coastal Treaty Tribes and the 

Olympic Coast Intergovernmental Policy Council, and honor the sanctuary‟s treaty trust 

responsibility. 

Goal B - Promote collaborative and coordinated management and stewardship of resources in the 

sanctuary. 

Goal E - Maintain the sanctuary‟s natural biological diversity and protect, and where appropriate, 

restore and enhance sanctuary ecosystems. 

Goal G - Facilitate wise and sustainable use in the sanctuary to the extent that such uses are 

compatible with resource protection. 

Background:

The potential release of oil or other hazardous material from a marine accident is widely seen as 

the greatest threat to sanctuary resources and qualities. Prevention of spills is therefore one of the 

sanctuary‟s highest priorities. As a steward of these vitally important natural resources, OCNMS

must continue to collaborate with other agencies and user groups to reduce the potential for oil 

spills and improve contingency planning for spill response.

Preventing, preparing for, and responding to hazardous spills continue to be high priorities for 

OCNMS. Additionally, better support for the damage assessment and restoration process is also 

a high priority. During the MPR process a spills working group was formed to bring together 

area experts to discuss OCNMS‟ role in regional spills prevention, preparedness, response and 

restoration efforts. The strategies and activities below reflect the recommendations of this 

working group.

Strategy SPILL1: ATBA MANAGEMENT, COMPLIANCE AND MONITORING

Sustain or improve the maritime industry‟s compliance with the Area to be Avoided (ATBA).

Activity A: Work with the USCG to prepare a proposal to the International Maritime 

Organization Subcommittee on Safety to Navigation to implement legislation requiring that 

voluntary “restrictions apply to all vessels required to prepare a response plan pursuant to 

Section 311(j) of the Federal Water Pollution Control Act (33 U.S.C. 1321(j)) (other than 

fishing or research vessels while engaged in fishing or research within the area to be 

avoided)” (Section 704, Coast Guard Authorization Act for Fiscal Years 2010 and 2011).

Activity B: Monitor voluntary compliance with the ATBA by conducting monthly 

processing of radar data from the jointly operated Canada/U. S. Cooperative Vessel Traffic 

Service (CVTS), augmented with Marine Exchange of Puget Sound Automated Identification 

System (AIS) data. Analyze vessel traffic patterns, track and identify the type and status of 

vessels that travel within OCNMS and the ATBA. Archive data to be able to identify trends 

in activity.
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Activity C: Improve the OCNMS vessel monitoring program by developing the capability to 

view, analyze and archive vessel data within the entire sanctuary using AIS data.

Activity D: Conduct directed outreach to non-compliant vessels. Send letters jointly signed 

by the OCNMS Superintendent and U.S. Coast Guard Captain of the Port requesting

compliance with the ATBA.

Activity E: Promote and facilitate reporting of ATBA compliance statistics and analysis to 

vessel traffic and oil spill prevention interests. This includes providing compliance data to 

Washington Department of Ecology (WDE) for inclusion within their annual Vessel Entry 

and Transit (VEAT) Report.

Activity F: Make ATBA compliance information available to regional marine spatial 

planning efforts and to the public.

Strategy SPILL2: REGIONAL VESSEL MANAGEMENT FORUMS

Work within regional vessel management forums to analyze and reduce risks and hazards. 

Activity A: Encourage and collaborate in review and development of Standards of Care 

(SOC) identifying accepted best marine practices for engaging in coastal towing operations 

off the Olympic Coast. Actively participate in local public meetings and comment on the 

USCG‟s proposed towing vessel inspection regulations with the goal of encouraging the 

earliest implementation of appropriate final rules.

Activity B: After SOCs are developed, utilize ATBA monitoring information to advise the 

USCG and industry of apparent non-compliance with developed SOCs. 

Activity C: Encourage the USCG, in collaboration with the U.S. Army Corps of Engineers 

(USACE) vessel traffic risk assessment, to analyze vessel traffic patterns and risks, 

particularly in the vicinity of Duntze Rock, Tatoosh Island, and Duncan Rock, and to 

determine whether additional protective measures (e.g., additional aids to navigation or new 

routing schemes) are required for safer navigation.

Strategy SPILL3: REGIONAL PLANNING AND TRAINING EXERCISES

Promote improved spill preparedness and response through OCNMS participation in training 

exercises and regional oil spill planning activities.

Activity A: Engage in regional efforts to promote, plan and conduct comprehensive drills 

and exercises.

 Promote regular testing and coordination of multiple response assets, equipment 

deployment, wildlife recovery and treatment equipment, emergency response tug 

located at Neah Bay, USCG emergency towing resources, communication systems, 

and natural resource damage assessment resources in these drills and exercises.

 Integrate OCNMS assets, including staff and vessels, into regional emergency 

response drills, exercises, and area contingency planning.

Activity B: Develop training/exercises, in conjunction with key partners, that target specific 

issues and concerns relevant to OCNMS and partners to improve planning and overall 

readiness. 
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 Training and exercise topics could include roles and responsibilities of various 

Incident Command System positions; dispersant consultation process; waste 

management tradeoffs; shoreline cleanup assessment technology training; shoreline 

treatment tactics; cleanup endpoints for different shoreline types; natural resource 

damage assessment; liaison function with key stakeholders; lessons learned from 

recent spills and exercises

Activity C: Collaborate in planning and conduct, if feasible, an exercise to test debris 

removal from remote shoreline locations. 

 Test and evaluate issues and methods useful for pre-cleaning beaches and removing 

oily waste materials during response operations. 

 If successful, promote regular exercise of safe and effective methods.

 Partner on debris removal projects with USCG and outer Olympic Coast land owners 

(Olympic National Park, Washington Maritime National Wildlife Refuge Complex, 

Coastal Treaty Tribes).

Activity D: Participate in technical workgroups and task forces of the Regional Response 

Team (RRT) and Northwest Area Committee (NWAC).

 Support integration of OCNMS priorities, data, and equipment into the Northwest Area 

Contingency Plan.

 Key workgroups and task forces include Volunteers; Response Science and Technology; 

Geographical Response Plans; Wildlife; and Communications and Outreach (separate 

activities for key NWAC workgroups are provided below).

Activity E: Assist in the review, development and improvement of Geographic Response 

Plans (GRPs) of the NWAC focusing on initial resource protection. 

 Potential areas for GRP improvement include protection of cultural resources and 

threatened and endangered species, equipment appropriate for the operating 

environment, and additional shoreline protection strategies.

Activity F: Participate in the Response Science and Technology workgroup of the NWAC to 

develop a Shoreline Operational Guide. 

 The Shoreline Operational Guide will address treatment tactics and cleanup endpoints 

for affected shorelines, proposed monitoring and other requirements for sensitive 

resources or habitats, and waste management guidelines.

 Promote integration of this Guide and its development into the Area Committee 

process.

Activity G: Participate in the Response Science and Technology workgroup of the NWAC to

develop a dispersant use matrix that summarizes spatial and temporal data related to natural 

resources in the water column that could potentially be impacted by dispersed oil. 

 Provide data held by OCNMS.

 Facilitate assembly and incorporation of data from NMFS.

Activity H: Support NWAC efforts to promote a strong non-dedicated vessel program 

including use of local resources, including fishing vessels regularly based in Neah Bay, La

Push, and the Grays Harbor area. 
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Activity I: Participate in the Places of Refuge workgroup of the NWAC in the evaluation of 

areas adjacent to OCNMS. 

Activity J: Support development of a digital environmental sensitivity index database and 

maps of Washington‟s outer Olympic Coast.

Activity K: Participate in US/Canada transboundary spill response planning through the 

Pacific States/British Columbia Oil Spill Task Force.

Strategy SPILL4: OUTER COAST TRUSTEES WORKING GROUP

Promote improved regional preparedness for spill response through coordination of an ad hoc 

Outer Coast Trustees working group (state of Washington, Coastal Treaty Tribes, local 

governments, National Park Service, U.S. Fish and Wildlife Service, Parks Canada) as a forum 

to share information and training opportunities.

Activity A: Maintain a current contact list for natural and cultural resource trustees, natural 

resource managers, and spill response leads from agencies and organizations on the outer 

coast of Washington.

 Include multiple means of communication (office and cell phone numbers, emails, 

agency emergency contact numbers, pagers) on contact list.

 Coordinate with RRT to regularly update the Northwest Area Contingency Plan.

Activity B: Identify opportunities for joint training and information sharing related to 

regional preparedness for spill response, and promote regional participation through the 

Outer Coast Trustees.

Activity C: Identify emergency response plans developed by co-trustees and collaborate with 

co-trustees to minimize inconsistencies and maximize the effectiveness of these plans.

Strategy SPILL5: OCNMS ORGANIZATIONAL RESPONSE PLAN

Develop policies, tools and procedures for OCNMS staff and resource mobilization, OCNMS 

integration into an Incident Command Structure, and effective consultation on emergency 

response actions.

Activity A: Develop an OCNMS Organizational Response Plan. 

 Ensure consistency between the OCNMS Organizational Response Plan and 

Northwest Area Contingency Plan (NWACP).

 Integrate OCNMS information, policy and procedures into the NWACP, as 

appropriate.

 Identify OCNMS staff training requirements and needs for emergency response, and 

maintain appropriate training levels.

 As part of the plan, consider an outreach policy that explains how OCNMS will

liaison with key stakeholders, the public, elected officials and co-trustees within their 

shared boundaries during spill responses.

 Develop a clear process or decision tool to identify steps for dispersant, in-situ burn, 

or shoreline chemical use decision-making by OCNMS to support consultation with 

co-trustees, the FOSC, and the RRT consistent with the NWACP.
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 Identify training opportunities for OCNMS volunteers to improve their ability to

participate in spill response.

Activity B: Develop a database that includes natural and cultural resource information useful 

for shoreline protection countermeasures, as well as evaluation of potential resource impacts 

from spilled petroleum products and associated response activities. 

 Assemble the most current and detailed data available for the region.

 Utilize effective technologies to access, display and analyze resource information.

 Collaborate with regional resource managers, co-trustees, response organizations and 

the RRT to share data, tools, and products.

 Regularly complete updates and improvements to these data and tools.

Activity C: Work with the Office of National Marine Sanctuaries and NOAA Office of 

Response and Restoration to regularly update and improve SHIELDS (Sanctuary Hazardous 

Incident Emergency Logistics Database System).

Strategy SPILL6: DAMAGE SURVEY AND ASSESSMENT PROTOCOLS

Collaborate in regional efforts to develop plans, protocols, capacity and baseline data to support 

natural resource damage assessment (NRDA) efforts. 

Activity A: Collaborate with co-trustees of resources in the sanctuary to develop an Outer 

Coast NRDA Response Plan that includes: 

 Notification requirements

 Prioritized objectives

 Supplies and equipment for ephemeral data collection

 Standardized protocols for ephemeral data collection

 Identification of beach access points 

 Property access permissions

 Cultural resource considerations and points of contact

 Lists of response resources (vessels, aircraft, personnel) that could be hired for 

NRDA purposes (vs. spill response clean-up efforts)

 Data quality objectives

 Training recommendations and requirements

Activity B: Collaborate with co-trustees to improve capabilities for NRDA work.

 Integrate NRDA components into local and regional response exercises.

 Seek funding to support participation in NRDA planning and training opportunities.

 Review and revise response plans, as appropriate, following incidents that include 

NRDA efforts.

 Inventory, purchase, place, and maintain ephemeral data collection equipment on the 

outer coast.

Activity C: Collaborate with co-trustees to identify natural and cultural resources most 

vulnerable to oil spills and prioritize baseline data collection for species and services useful 

for NRDA.

 Outline needed data and studies.
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 Assemble existing data into a database for baseline information on natural and 

cultural resources.

 Determine who can conduct additional studies and sampling.

 Seek funding to support baseline data collection.

Activity D: Participate in any restoration projects, should they occur, within sanctuary 

boundaries or directly affecting the sanctuary through phases of planning, implementation, 

and monitoring. Coordinate with other trustees with responsibilities for affected resources 

and provide data and input to support decision-making.

Links to other Action Plans: Collaborative and Coordinated Sanctuary Management, Marine 

Debris, Wildlife Disturbance, Sanctuary Operations, Regional Ocean Planning

Key Partners: USACE Seattle District; Puget Sound Harbor Safety Committee; Canadian Coast 

Guard Marine Communications and Traffic Services, Tofino; Marine Exchange of Puget Sound; 

Makah Office of Marine Affairs; Makah, Quileute and Hoh Tribes and Quinault Indian Nation; 

American Waterways Operators; U.S. Navy (for movement of reactor core by barge); Lower 

Columbia Region Harbor Safety Committee; United States Coast Guard Thirteenth District 

Commander; Sectors Puget Sound and Columbia River; Canadian Coast Guard Marine 

Communications and Traffic Services Tofino; Marine Exchange of Puget Sound; Washington 

Department of Ecology; Washington Department of Fish and Wildlife; Washington Department 

of Natural Resources, Washington Department of Archaeology and Historic Preservation; 

Washington State Parks and Recreation Commission; Washington Resource Damage 

Assessment Committee; marine resource committees (MRCs); other natural resource trustees; 

on-scene spill response organizations; NOAA Office of Response and Restoration; NOAA 

Restoration Center; Department of Interior NRDA staff; Canadian Coast Guard; Canadian First 

Nations; Transport Canada , Olympic National Park; Washington Maritime National Wildlife 

Refuge Complex/U.S. Fish and Wildlife Service; U.S. Coast Guard; Clallam, Jefferson, and 

Grays Harbor counties; Parks Canada; NMFS; Northwest Area Committee and Regional 

Response Team members; OCNMS volunteers; academic institutions
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D2. Climate Change Action Plan

Desired Outcomes: 1) OCNMS is a sentinel site in the Pacific Northwest for climate change 

monitoring; 2) OCNMS is a go-to source for climate change information on Washington‟s outer 

coast marine ecosystems; and 3) ONMS understands and is prepared for likely climate change 

impacts in the sanctuary region.

Links to Goals: 

Goal C - Investigate and enhance the understanding of ecosystem processes, and inform 

ecosystem-based management efforts, through scientific research, monitoring, and 

characterization. 

Goal E - Maintain the sanctuary‟s natural biological diversity and protect, and where appropriate, 

restore and enhance sanctuary ecosystems. 

Goal G - Facilitate wise and sustainable use the sanctuary to the extent that such uses are 

compatible with resource protection. 

Goal H- Build, maintain, and enhance an operational capability and infrastructure. 

Background:

The public repeatedly raised concerns about climate change and its potential effects on 

organisms and ecosystems within the sanctuary during the MPR scoping process. Additionally, 

the Olympic Coast Intergovernmental Policy Council (IPC) and the OCNMS Advisory Council 

(AC) identified climate change as a high priority to be addressed in the revised management 

plan.

Climate change is an ecosystem management issue cutting across all disciplines and will be 

addressed by all of OCNMS‟ program areas over the next decade. Indeed, references to climate 

change can be found in strategies and activities throughout this management plan. Because 

climate change is expected to be such an important issue for the sanctuary, it was important to 

highlight the issue in its own action plan. Other action plans reference ways in which individual 

OCNMS programs will address aspects of the climate change topic, but this action plan is 

focused on how ONMS will coordinate its efforts across program areas in order to address 

climate change in a holistic and interdisciplinary way. This action plan also promotes OCNMS 

as a sentinel site for ocean acidification and climate change research. Sentinel sites are locations 

in the marine environment that support sustained observations of changes in the status of the 

marine environment. They allow investigators to track the status of key indicators of ecosystem 

integrity, serve as a means to provide early warning to resource managers, and offer 

opportunities for protocol testing. They address NOAA activities in areas of mandated 

responsibility and help address questions about regional issues such as habitat degradation and 

invasive species impacts.

Strategy CLIM1: CLIMATE-SMART SANCTUARY PROGRAM

Participate in the Office of National Marine Sanctuaries Climate-Smart Sanctuaries program in 

order to become certified as a climate-smart sanctuary. 

Activity A: Conduct an audit of OCNMS‟ carbon footprint and determine what changes are 

needed to ensure OCNMS meets the minimum green operating standards outlined in the 

Climate-Smart Sanctuary guidelines.
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Activity B: Develop a Climate Change Site Scenario for OCNMS synthesizing the best 

available information on climate change impacts to present a picture of what the sanctuary

might look like in 50 to 100 years.

Activity C: Work with the AC and IPC to review (and revise if necessary) this Climate 

Change Action Plan based upon the findings of the Climate Change Site Scenario.

Activity D: Brief the AC and IPC on OCNMS‟ Climate-Smart Sanctuary certification 

process, and ensure information compiled for Climate Smart Sanctuary certification is widely 

distributed to OCNMS partners and the public.

Strategy CLIM2: SANCTUARY AS SENTINEL SITE

Work to establish OCNMS as a sentinel site for long-term climate change research and 

monitoring in the Pacific Northwest.

Activity A: Propose to NOAA leadership that OCNMS be identified as a sentinel site for 

climate change research and monitoring. 

Activity B: Work with the AC to establish a climate change working group to help 1) 

develop a climate change research prospectus describing specific climate change research 

priorities for the sanctuary, and 2) identify marine chemical, physical, and biological 

indicators of climate change that OCNMS and partners should consider monitoring. 

Activity C: Provide relevant scientific and technical information to the Washington 

Department of Ecology to support the State‟s central climate change information 

clearinghouse and utilize this clearinghouse to support OCNMS research and planning 

efforts. 

Strategy CLIM3: RESILIENT ECOSYSTEMS

Work with natural resource managers and local communities on the Olympic Peninsula to 

improve the resiliency of ecosystems in the face of climate change impacts. 

Activity A: Work with the AC to establish a climate change working group to provide 

recommendations to ONMS, and to collaborate with tribal, federal, state and local 

governments on potential joint management responses to climate change impacts.

Activity B: Participate in the state of Washington‟s integrated climate change response 

strategy as well as in other regional efforts to develop and understand climate change impacts 

to natural and cultural resources.

Activity C: Host workshops and provide training for OCNMS staff and local communities 

on the outer coast on planning, mitigating for, and managing climate change impacts.

Strategy CLIM4: COMMUNICATING CLIMATE CHANGE

Communicate information about climate change and its potential effects on the sanctuary and 

Washington‟s outer coast to OCNMS partners and the public.

Activity A: Ensure information and data collected by OCNMS on climate change and its 

effects on the sanctuary are readily available to other resource managers and interested 

parties.
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Activity B: Provide local communities and the public with information about potential 

climate change impacts on the Olympic Coast and local, tribal, state and regional efforts to 

plan for climate change.

Activity C: Work with tribal communities to develop public outreach materials that convey 

tribal perspectives on climate change and its potential effects on tribal communities.

Activity D: Promote education and outreach elements in climate change research projects 

that occur within OCNMS. 

Activity E: Develop a Climate Literacy education and outreach plan and incorporate it into 

OCNMS‟ Ocean Literacy Action Plan. 

Links to Other Action Plans: Collaborative and Coordinated Sanctuary Management, Physical 

and Chemical Oceanography, K-12 Education, Higher Education, Visitor Services, Data 

Management, Sharing, and Reporting

Key Partners: Hoh, Makah, and Quileute tribes and Quinault Indian Nation, Washington State 

Ocean Caucus, UW Climate Impacts Group, West Coast Governors‟ Agreement on Ocean 

Health Climate Change Action Coordination Team, NOAA/PMEL, OCNMS Advisory Council, 

West Coast Regional Sanctuaries, Monterey Bay Research Institute, Grays Harbor and North 

Pacific Coast marine resources committees, Washington Sea Grant, Port Townsend Marine 

Science Center, UW Friday Harbor Labs, U.S. Fish and Wildlife Service, Olympic National 

Park, NOAA Ocean Services, and non-governmental organizations, AC, NOAA (ONMS, 

NMFS, PMEL), NGOs, IPC, Washington Department of Ecology
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D3. Marine Debris Action Plan

Desired Outcomes: 1) Increased identification of the types and locations of abandoned 

submerged and floating marine debris; and 2) reduced environmental and aesthetic impacts of 

debris on coastal beaches.

Links to Goals: 

Goal E - Maintain the sanctuary‟s natural biological diversity and protect, and where appropriate, 

restore and enhance Sanctuary ecosystems. 

Background:

Manufactured materials disposed of in the ocean are known as marine debris; these debris are 

unsightly on our beaches, harmful to wildlife, and can reduce fishery profits. Removing marine 

debris from the ocean and beaches, and working with partners to reduce the production and 

disposal of materials that frequently become marine debris, are both important to protecting the 

health of the sanctuary and the wildlife that inhabit it. This action plan outlines the strategies and 

activities by which OCNMS will continue and expand its efforts to reduce marine debris in and 

prevent it from entering the sanctuary. 

OCNMS formally defines marine debris, in accordance with the NOAA Office of Response and 

Restoration Marine Debris Program‟s definition, as “any persistent solid material that is 

manufactured or processed and directly or indirectly, intentionally or unintentionally, disposed of 

or abandoned into the marine environment.” Marine debris can be submerged or floating in the 

ocean; it can also be beached. Submerged marine debris includes sunken, derelict vessels. 

Marine debris removal and reduction, in addition to being a high priority for OCNMS, is also a 

high priority for the state of Washington, the Coastal Treaty Tribes, non-governmental

organizations such as Surfrider and a wide range of other organizations and agencies. Affecting 

ocean and beach ecosystems all over the world, marine debris is a global ocean epidemic. Thus, 

in supporting local marine debris efforts, OCNMS is also helping to promote nation and 

worldwide awareness of the marine debris problem.

Strategy MD1: SUBMERGED OR FLOATING DEBRIS

Identify, locate, and remove lost or abandoned submerged or floating marine debris.

Activity A: Promote use by tribal and non-tribal fishers of the Washington Department of 

Fish and Wildlife (WDFW) derelict fishing gear hotline, Northwest Straits Marine 

Conservation Initiative derelict fishing gear reporting system, or other systems established 

for reporting locations of lost fishing gear, sunken vessels, and other forms of submerged and 

floating marine debris.

Activity B: Support programs focusing on Washington‟s outer coast to locate abandoned 

submerged and floating marine debris, develop safe and minimal impact removal techniques, 

and remove known marine debris. 

Activity C: Support local efforts to reduce generation of sea-based marine debris through 

improvements in opportunities for solid waste and marine debris disposal and recycling 

programs. 
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Activity D: Record observations of abandoned submerged and floating marine debris made 

during OCNMS research and monitoring programs. Report relevant observations to WDFW, 

Northwest Straits Marine Conservation Initiative and/or other appropriate reporting systems. 

Activity E: Maintain an OCNMS database and geographic information system (GIS) 

products for marine debris identified by OCNMS and others. Collaborate in efforts to 

prioritize removal of submerged and floating marine debris.

Activity F: Collaborate with the U.S. Department of Defense to mitigate military use of 

expendable materials that become marine debris.

Strategy MD2: BEACH DEBRIS

Mitigate impacts of marine debris on coastal beaches.

Activity A: Participate as an active partner in the Washington Clean Coast Alliance 

(WCCA). Engage coastal communities and volunteers in beach cleanups, including 

expansion of efforts to include multiple volunteer beach cleanup efforts on shores adjacent to 

the sanctuary throughout the year. 

Activity B: Conduct outreach to increase public understanding of the nature and scope of 

environmental impacts of marine debris, and encourage individual efforts to reduce sources 

of marine debris. 

Activity C: Collaborate with Olympic National Park and the Washington Maritime National 

Wildlife Refuge Complex to develop beach cleanup initiatives focused on refuge island 

shores and remote coastal areas of the park.

Activity D: Promote inventory of marine debris from Washington‟s outer coast beaches. 

Use marine debris data in public outreach efforts and to support regional efforts to reduce 

sea- and land-based sources of marine debris.

Activity E: Support programs in coastal communities to identify potential sources of landbased marine debris, and improve garbage management, recycling opportunities and other 

programs with potential to reduce beach debris. 

Activity F: When feasible, collaborate with the U.S. Department of Defense to use military 

manpower and equipment to support beach cleanups and other marine debris removal efforts 

in the sanctuary.

Links to Other Action Plans: Collaborative and Coordinated Sanctuary Management, 

Community Outreach, Community Involvement in Sanctuary Management, Habitat Protection, 

Spills

Key Partners: Hoh, Makah, and Quileute tribes and Quinault Indian Nation, coastal 

communities, Washington Clean Coast Alliance, NOAA Marine Debris Program, West Coast 

Governors‟ Agreement on Ocean Health Marine Debris Action Coordination Team, Washington 

state, Olympic National Park, Washington Maritime National Wildlife Refuge Complex, U.S. 

Department of Defense, North Pacific Coast and Grays Harbor marine resources committees, 

Northwest Straits Marine Conservation Initiative, non-governmental organizations, and regional 

port authorities
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D4. Wildlife Disturbance Action Plan

Desired Outcomes: 1) Minimized disturbance to wildlife in the sanctuary; and 2) improved 

protection for wildlife potentially impacted by human activities.

Links to Goals: 

Goal E - Maintain the sanctuary‟s natural biological diversity and protect, and where appropriate, 

restore and enhance sanctuary ecosystems. 

Background:

During the MPR public scoping process, numerous comments identified protection of wildlife, 

including minimization of wildlife disturbance from human activities, as an important topic for 

sanctuary management. The outer coast of Washington, particularly the northern portion, is 

recognized for its unique and abundant wildlife, relatively undeveloped condition, and 

productive ecosystem through state and federal designations – Washington Seashore 

Conservation Area, Olympic National Park‟s coastal strip, Washington Maritime National 

Wildlife Refuge Complex, and Olympic Coast National Marine Sanctuary. These extraordinary 

natural values were acknowledged and protected as early as 1907 when seabird colonies on the 

coast‟s islands were first granted federal conservation protection under a seabird reserve system 

by President Theodore Roosevelt.

The phrase „wildlife disturbance‟ encompasses acoustic, physical and visual disturbances caused 

by human activities that can have physical and behavioral impacts on wildlife above, below and 

on the water surface. Overt responses of fish and wildlife species to disturbance include flushing 

birds from their nesting roosts, flushing of marine mammals from haul out areas, or even death. 

Sources of wildlife disturbance in OCNMS could include low-flying aircraft, motorized personal 

watercraft, fireworks, close approach to wildlife aggregation areas (either humans on foot or in a 

vessel) and other excessive anthropogenic noises that could originate from shipping, military 

exercises, or seismic exploration. Research has documented variability in disturbance distances 

and responses based on differing activities and vessel types, as well as on the species affected. 

In marine areas, these data have supported protective regulations to establish approach limits, 

speed restrictions and buffer zones around sensitive wildlife assemblages and habitats. Wildlife 

disturbance also can be minimized through outreach both to expand citizen familiarity with 

issues and to encourage appropriate behavior around wildlife. 

The focus of this action plan is on working collaboratively to improve outreach, education and 

enforcement efforts related to wildlife disturbance, as there are existing regulations (OCNMS, 

USFWS, NMFS) addressing wildlife disturbance concerns and impacts. However, awareness 

and enforcement of these regulations is inadequate and greater efforts need to be made to 

improve:

 Sanctuary users‟ understanding of appropriate and mandated wildlife etiquette

 Voluntary compliance with wildlife disturbance regulations so impacts to wildlife are 

avoided

 Enforcement of wildlife disturbance regulations so future impacts to wildlife are reduced
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FINAL MANAGEMENT PLAN

Strategy WD1: OUTREACH ON WILDLIFE DISTURBANCE

Promote public understanding of wildlife disturbance issues through education and outreach 

programs. 

Activity A: Collaborate with other wildlife management agencies in the region to develop 

wildlife viewing guidelines addressing shore-based and vessel activities. Produce and 

distribute those outreach products that address wildlife viewing guidelines.

Activity B: Collaborate on outreach efforts targeting specific user groups in order to improve

public understanding of wildlife disturbance and the impacts of human behavior on wildlife. 

Promote best practices, guidelines and regulations that benefit wildlife, reduce disturbance, 

and enhance human enjoyment of natural resources. 

 Model programs include NOAA‟s Ocean Etiquette and Watchable Wildlife.

 User groups include charter fishing and wildlife viewing operators, kayakers and 

surfers.

 During outreach efforts, identify legitimate uses of the airspace within the OCNMS 

wildlife disturbance mitigation (overflight restriction) zone.

Activity C: Collaborate in training regional interpreters, rangers, enforcement staff and 

volunteers on wildlife disturbance issues.

Activity D: Improve OCNMS web site content related to visitor appreciation of wildlife and 

wildlife disturbance caused by human activities.

Activity E: Maintain the OCNMS incident database to record times, locations, and other 

information for reported wildlife disturbance events.

 Incident database entries will include reported overflight violations, as well as 

permitted and exempted low altitude flights.

 Include marine mammal ship strikes in the database.

 Incident database information will be shared with regional enforcement officers, 

permitting staff and concerned management entities to reinforce wildlife disturbance 

concerns.

Strategy WD2: OVERFLIGHT RESTRICTION ZONE

Support and improve recognition of and compliance with the existing OCNMS wildlife 

disturbance mitigation (overflight restriction) zone. 

Activity A: Improve compliance with the OCNMS wildlife disturbance mitigation 

(overflight restriction) zone through collaboration with Aircraft Owners and Pilots 

Association (AOPA) and Washington Pilots Association (WPA) to improve outreach 

products for and communication with local pilots. 

Activity B: Develop outreach products and orientation materials on the OCNMS wildlife 

disturbance mitigation (overflight restriction) zone and associated wildlife disturbance issues 

useful for regional enforcement officers. Organize and conduct regular training sessions for 

regional enforcement officers.

Activity C: Support efforts to have the OCNMS wildlife disturbance mitigation (overflight 

restriction) zone depicted on Federal Aviation Administration (FAA) aeronautical charts. 
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Strategy WD3: MARINE MAMMAL DISTURBANCE

Assess the potential for and occurrence of marine mammal disturbance and injury from human 

activities.

Activity A: Participate and encourage activities to characterize the acoustic environment and 

potential acoustic impacts on marine mammals in the sanctuary including:

 Supporting long-term acoustic monitoring to establish background sounds levels and 

changes over time

 Collaborating with researchers and other agencies to identify potential emerging 

issues related to sources of underwater sound that could impact the sanctuary 

environment

 Considering how proposed activities in and around sanctuary waters might generate 

underwater sound that could impact marine mammals

Activity B: Identify degree of risk posed to marine mammals from ship strikes in the 

sanctuary by: 

 Coordinating with the Northwest Marine Mammal Stranding Network to identify 

potential increased incidences of ship strikes that may have occurred in the sanctuary

 Supporting efforts to examine overlap areas of high marine mammal density and 

shipping lanes

 Assessing acoustic impact mitigation strategies used by other sanctuaries and NOAA 

agencies and considering such strategies in OCNMS

Activity C: Work with the fishery co-managers and fishing organizations to identify existing 

conflicts between marine mammals and other activities in the sanctuary including:

 Marine mammal entanglement in fishing and other gear occurring in sanctuary waters

 New emerging conflicts such as those between long-line fishing operations and 

depredating sperm whales (i.e., whales that are taking or trying to take fish from 

fishing gear)

Links to other Action Plans: Sanctuary Operations, Habitat Protection, Populations, 

Communities and Ecosystems, Visitor Services, Community Outreach, Collaborative and 

Coordinated Sanctuary Management, Physical and Chemical Oceanography

Key Partners: Hoh, Makah, and Quileute tribes and Quinault Indian Nation, Olympic National 

Park, U.S. Fish and Wildlife Service, Washington State Parks and Recreation Commission, 

Washington Department of Fish and Wildlife, COASST, Washington Clean Coast Alliance; 

Grays Harbor and North Pacific Coast marine resource committees, Surfrider, NMFS, Westport 

Charterboat Association, regional port authorities and marina facilities, Northwest Marine 

Mammal Stranding Network, U.S. Coast Guard, U.S. Navy, Aircraft Owners and Pilots 

Association (AOPA), Washington Pilots Association (WPA), regional airports, shipping 

industry, coastal communities
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D5. Water Quality Protection Action Plan

Desired Outcome: High water quality to ensure protection of natural resources in the sanctuary

Links to Goals: 

Goal E - Maintain the sanctuary‟s natural biological diversity and protect, and where appropriate, 

restore and enhance sanctuary ecosystems. 

Background:

ONMS strives to maintain and improve water quality in the sanctuary. Water quality protection 

is critical to ensuring the health of marine organisms and habitats from the bottom to the top of 

the food chain. Given increasing concerns about ocean acidification, harmful algal blooms and 

hypoxic events, it is crucial that OCNMS do its utmost to identify, mitigate, reduce and/or 

remove, where possible, known causes of water quality degradation in the sanctuary.

Strategy WQP1: VESSEL DISCHARGES

Reduce, through regulatory changes, voluntary and outreach measures, or marina facilities 

improvements, the degradation of water quality caused by vessel wastewater and sewage 

discharges.

Activity A: Work with the shipping industry and others to assess potential impacts of 

wastewater discharges from large vessels (300 gross tons or greater) and identify measures to 

prevent or mitigate those impacts.

Activity B: During the management plan review process, publish a rulemaking proposing to 

modify OCNMS regulations to prohibit all discharges from cruise ships into sanctuary 

waters, except those necessary for vessel operations (e.g., clean vessel engine cooling water, 

clean vessel generator cooling water, clean bilge water, engine exhaust, and anchor wash). 

Activity C: Encourage regional port authorities, and assist in their efforts, to improve 

availability and use of sewage pump-out facilities for vessels. 

Activity D: Work collaboratively with coastal communities to develop and implement a 

water quality education and outreach program to promote best practices regarding vessel 

discharges from marine sanitation devices, or those vessels lacking marine sanitary devices.

Activity E: In year five of management plan implementation review the progress made on 

activities WQP1 A-D, and evaluate if additional actions are warranted.

Strategy WQP2: CONTAMINANTS

Support efforts to monitor contaminant levels, understand potential impacts of contaminants, and 

reduce, eliminate, or mitigate impacts of contaminants to natural resources in the sanctuary. 

Activity A: Support local, state, tribal and federal efforts to identify, characterize, and 

mitigate sources of contaminants within or entering waters of the sanctuary and accumulating 

in biota and habitats.

Activity B: Support closure and remediation of the Warmhouse Dump (on Makah Tribe‟s 

Reservation) to minimize contaminant release to marine waters. 
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Links to other Action Plans: Physical and Chemical Oceanography, Collaborative and 

Coordinated Sanctuary Management

Key Partners: U.S. Environmental Protection Agency, Washington Department of Ecology, 

Hoh, Makah, and Quileute tribes and Quinault Indian Nation, local governments, coastal 

communities, outer coast Marine Resources Committees, Olympic National Park, Washington 

Maritime National Wildlife Refuge Complex, West Coast Governors‟ Agreement on Ocean 

Health Polluted Runoff Action Coordination Team, U.S. Department of Defense, nongovernmental organizations, regional port authorities, cruise ship industry, shipping industry, 

commercial fishing interests
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D6. Habitat Protection Action Plan

Desired Outcomes: Human-caused degradation of marine habitats is minimized and mitigated,

particularly for those habitats 1) demonstrating high value to ecosystem functioning and 

productivity; and 2) are most vulnerable to human disturbance.

Links to Goals: 

Goal E - Maintain the sanctuary‟s natural biological diversity and protect, and where appropriate, 

restore and enhance sanctuary ecosystems. 

Background:

The phrase „habitat protection‟ is used here to reference actions taken to prevent, mitigate, or 

eliminate degradation of marine habitats in the sanctuary. A fundamental premise of habitat 

protection actions is that healthy habitats support healthy marine populations and communities, 

including exploited fishery resources. Habitat protection actions must be supported by research 

and monitoring efforts that improve our understanding of functions and values of marine 

habitats, document how, when and where habitat degradation occurs, and evaluate the 

effectiveness of management responses. In addition, habitat protection actions need to be 

reinforced through outreach, both to expand citizen familiarity with issues and to encourage 

actions that individuals and organizations can take to minimize habitat impacts. 

This action plan focuses heavily on collaborative work to 1) understand potential habitat impacts 

in the sanctuary, 2) identify habitats of special concern critical to ecosystem functioning in the 

sanctuary, and 3) monitor for and prevent invasive species introductions.

Strategy HP1: THREAT ASSESSMENT AND MITIGATION

Assess existing and potential natural and human-caused threats to physical and biogenic marine 

habitats (e.g., deep sea corals and sponge, kelp and other macroalgae), and collaboratively 

develop appropriate management measures to protect and conserve physical and biological 

habitats.

Activity A: Identify, in consultation with co-management authorities, existing and potential 

impacts and threats to, as well as relative vulnerability of, physical and biogenic marine 

habitats in the sanctuary. Recommend and/or implement monitoring to assess relative habitat 

vulnerabilities to, and impacts and threats from natural disturbances and human activities, 

including cumulative impacts. 

Activity B: Recommend, or implement collaboratively with co-managers, management 

measures minimizing and mitigating human-caused impacts to physical and biogenic marine 

habitats. 

Activity C: Monitor the recovery rates of habitats, associated biological communities, and 

habitat-forming biogenic structures following disturbance by human activities. 

Strategy HP2: HABITATS OF SPECIAL IMPORTANCE

Develop criteria to identify marine habitats of special importance. Collaborate with co-managers 

to identify and implement management measures necessary for protection of habitats of special 

importance.
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Activity A: Develop criteria, in collaboration with natural resource co-managers, for habitat 

types of special importance to ecosystem function or managed species and identify the locations 

of such habitats.

Activity B: Develop and implement, in collaboration with natural resource co-managers,

potential management strategies for protection of habitats of special ecosystem value.

Activity C: Participate in Pacific Fishery Management Council processes, including 

identification and review of essential fish habitat (EFH) and habitat areas of particular concern 

(HAPC) through OCNMS representation on the EFH Review Committee.

Activity D: Collaboratively develop and evaluate recommendations for HAPC site and EFH 

conservation areas. 

Activity E: Assist the National Park Service with designation and management of intertidal 

reserve areas as identified in the ONP 2008 General Management Plan. 

Strategy HP3: INVASIVE SPECIES

Reduce the potential for introduction of invasive species in the sanctuary region, monitor 

distributions of known invasive species, and support programs to mitigate impacts of invasive 

species to natural and cultural resources.

Activity A: Through OCNMS monitoring, stewardship and outreach programs, support the 

work of Washington State Department of Fish and Wildlife and other agencies to prevent 

introduction of invasive species.

Activity B: Engage in regional efforts to monitor for the presence and distribution of 

invasive species, including volunteer monitoring, where appropriate.

Activity C: Support regional efforts to develop a response protocol(s) for non-native 

invasive species and to reduce ecological and economic impacts of invasive species.

Links to Other Action Plans: Water Quality Protection, Populations, Communities and 

Ecosystems, Habitat Mapping and Classification, Collaborative and Coordinated Sanctuary 

Management

Key Partners: ONP, USFWS, USGS, NOAA (NMFS, NOS), Washington Departments of Fish 

and Wildlife, Ecology, and Natural Resources, Washington Invasive Species Council, Hoh, 

Makah, and Quileute tribes and Quinault Indian Nation, IPC, North Pacific Coast and Grays 

Harbor marine resources committees, NGOs, universities and colleges, coastal communities, 

Pacific Fishery Management Council, academic organizations, Department of Fisheries and 

Oceans Canada, local governments, and coastal communities
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D7. Regional Ocean Planning Action Plan

Desired Outcome: Improved integration of best available science into OCNMS decision 

making.

Links to Goals: 

Goal E - Maintain the sanctuary‟s natural biological diversity and protect, and where appropriate, 

restore and enhance Sanctuary ecosystems. 

Goal G - Facilitate wise and sustainable use in the sanctuary to the extent that such uses are 

compatible with resource protection. 

Background:

Throughout the MPR process, the issue of human development in the sanctuary – and how to 

facilitate human activities in the sanctuary compatible with the primary OCNMS objective of 

resource protection – has repeatedly arisen. The ocean is a busy place; there are many activities 

occurring in sanctuary waters and many activities that may be proposed in the near future. It is a 

complex task to facilitate human use of the sanctuary while maintaining adequate protection for 

resources. Each human use and its potential associated impacts need to be analyzed and 

understood; likewise, the cumulative impacts of all human uses need to be considered. 

Moreover, ONMS needs to understand potential conflicts between human uses. Thus, in order to 

make sound decisions about human use development in the sanctuary, ONMS cannot consider 

each human use in isolation. 

ONMS also needs to consider human uses in the sanctuary within the context of regional human 

use patterns and development. Currently, there are significant regional and national ocean 

planning efforts being made to address human use development in the ocean and balance 

development of ocean resources with the protection of these resources; these efforts are 

commonly described as “marine spatial planning.” The National Ocean Council describes 

coastal and marine spatial planning (CMSP) as:

“...a comprehensive, adaptive, integrated, ecosystem-based, and transparent 

spatial planning process, based on sound science, for analyzing current and 

anticipated uses of ocean, coastal and Great Lakes areas. CMSP identifies areas 

most suitable for various types of classes of activities in order to reduce 

conflicts among uses, reduce environmental impacts, facilitate compatible uses, 

and preserve critical ecosystem services to meet economic, environmental, 

security and social objectives. In practical terms, CMSP provides a public policy 

process for society to better determine how the ocean, coasts, and Great lakes 

are sustainably used and protected now and for future generations.” Executive 

Order 13547, Stewardship of the Ocean, Our Coasts, and the Great Lakes 

ONMS decisions about human use planning and permitting in the sanctuary should be informed 

by regional ocean planning efforts. And, conversely, those making ocean planning decisions 

about human uses on a regional scale will include OCNMS and its role in promoting marine 

conservation and ocean stewardship in their decision-making process. This action plan explains 

how ONMS will integrate itself into regional and other ocean planning efforts in order both to 
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make and promote sound decisions about compatible human use development in the sanctuary 

and the northwest region.

Strategy ROP1: REGIONAL OCEAN PLANNING

Investigate how recent initiatives in marine spatial planning can improve sanctuary management 

by participating in regional ocean planning processes. 

Activity A: Work with the IPC and AC to develop a plan to integrate sanctuary efforts into 

regional ocean planning processes.

Activity B: Make existing OCNMS spatial data available to existing marine spatial tools, 

such as the Multipurpose Marine Cadastre.

Activity C: Identify, prioritize and collect spatial data on marine uses and resources that 

contribute to regional ocean planning processes and improve ONMS decision-making.

Activity D: Support the state of Washington‟s efforts to develop a statewide Marine Spatial

Plan, as well as other regional and federal ocean planning efforts that may emerge in the 

future. 

Activity E: Participate in planning processes and site evaluations for proposed development 

projects in or immediately adjacent to OCNMS and utilize existing (or collaborate in 

collecting new) natural and cultural resource information to avoid, minimize, and mitigate 

user conflicts and impacts to habitats and natural and cultural resources. 

Links to Other Action Plans: Collaborative and Coordinated Sanctuary Management, 

Community Involvement in Sanctuary Management, Habitat Mapping and Classification, 

Habitat Protection, Wildlife Disturbance, Sanctuary Operations

Key Partners: Hoh, Makah, and Quileute tribes and Quinault Indian Nation, Department of 

Interior (National Parks, U.S. Fish and Wildlife Service), NMFS, Washington State Departments

of Fish and Wildlife, Natural Resources, and Ecology, Washington State Ocean Caucus, West 

Coast Governors‟ Agreement on Ocean Health Renewable Ocean Energy Action Coordination 

Team, West Coast CMSP Regional Planning Body, local governments, coastal communities and 

non-governmental organizations
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E. Understand the Sanctuary’s Cultural, Historical and Socioeconomic 

Significance

E1. Maritime Heritage Action Plan

E2. Socioeconomic Values of Resources in the Sanctuary Action Plan

Introduction

Characterizing, protecting, and enhancing public awareness of the sanctuary‟s maritime heritage 

(including living cultures, cultural resources, and local and customary knowledge) is an

important role of OCNMS – and a role mandated by Section 110 of the National Historic 

Preservation Act. Additionally, facilitating compatible and sustainable human uses of sanctuary 

resources is also an important role of OCNMS. In many cases, OCNMS does not have a strong 

understanding of the cultural, historical and socioeconomic significance of its resources. Thus, 

over the next five to ten years, OCNMS needs to work collaboratively with tribal and non-tribal 

communities, as well as with experts in archeology, anthropology, history, social sciences and 

economics to build this understanding and communicate maritime heritage messages effectively 

to the public.
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E1. Maritime Heritage Action Plan

Desired Outcomes: 1) Improved understanding of the cultural and historic resources in the 

sanctuary region; and 2) Improved communication between OCNMS, the Washington State 

Historic Preservation Office, the Makah Tribal Historic Preservation Office, and the Quileute, 

Hoh and Quinault cultural resource management representatives.

Links to Goals: 

Goal F - Enhance understanding and appreciation of the Olympic Coast‟s maritime heritage 

(living cultures, traditions, and cultural resources). 

Background:

The National Marine Sanctuaries Act (NMSA) mandates sanctuaries “enhance public awareness, 

understanding, appreciation, and wise and sustainable use of the marine environment, and the 

natural, historical, cultural and archeological resources of the National Marine Sanctuary System 

(NMSA, Section 301(b)(4)).” The NMSA also mandates sanctuaries comply with the federal 

archeological program, of which the National Historic Preservation Act is the primary tenant. 

It is important OCNMS continue to characterize and understand the cultural and historical 

resources in the sanctuary, particularly in light of the unique American Indian cultural context 

within which the sanctuary resides. While OCNMS‟ maritime heritage program is small in size, 

it can play a significant role in understanding and communicating the outer coast‟s rich cultural 

heritage to the public. The aim of this action plan is to define OCNMS‟ unique role in working 

collaboratively with tribal and non-tribal communities on the outer coast to:

 Continue and develop efforts to understand the region‟s rich cultural heritage

 Improve the public‟s understanding of the significance of the region‟s maritime heritage

 Incorporate local and customary knowledge (knowledge gained by experience and 

collected by tribal and non-tribal individuals and communities) into sanctuary 

management processes

 Gain an improved understanding of the past in order to make better ocean management 

decisions and policies today

One reason OCNMS‟ maritime heritage program is especially important to develop is the 

sanctuary area is also the usual and accustomed areas of four Coastal Treaty Tribes. In this way, 

OCNMS is unique within the national marine sanctuary system; and the interconnectedness 

between the American Indians of the Olympic Peninsula and the ocean resources that are now a 

part of the sanctuary presents OCNMS with a unique opportunity and responsibility to work with 

the Coastal Treaty Tribes on maritime heritage projects and to communicate to the public the 

significance of tribal cultures. The non-tribal fishing communities adjacent to the sanctuary also 

possess a rich cultural heritage that OCNMS has a role in exploring and communicating. In 

addition to the cultural heritage of the region, a multitude of physical cultural resources exist in 

the sanctuary. Heavily-used historical and contemporary trade routes run through OCNMS and 

there are hundreds of shipwrecks supposed to have occurred in the sanctuary, only a handful of 

which have been verified, mapped and assessed. 
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This action plan identifies several specific ways in which OCNMS can more fully develop its 

maritime heritage program, improve its understanding of this heritage, and improve the way it 

communicates information about maritime and cultural heritage to the public.

Strategy MH1: CULTURAL RESOURCE CONSERVATION

Work collaboratively to locate, inventory, assess, interpret and protect cultural resources in the 

sanctuary, and develop further the cultural resource components of OCNMS‟ permitting and 

compliance program.

Activity A: Identify priorities for future cultural resource surveys in the sanctuary and assess 

the resources needed to complete those surveys and implement OCNMS‟ maritime heritage 

program.

Activity B: Work with partners to develop uniform guidelines/protocols for cultural resource 

data collection in the sanctuary.

Activity C: In consultation with the Coastal Treaty Tribes, the state of Washington Historic 

Preservation Office, the state of Washington Department of Historic Preservation and 

Archeology, Olympic National Park and others develop a programmatic agreement 

describing the way in which OCNMS‟ routine activities will comply with Section 106 of the 

National Historic Preservation Act. 

Activity D: Pursue research funding and partnerships with academic institutions and tribal 

communities to support the study and analysis of existing cultural resource collections (e.g., 

at the Makah Cultural and Research Center and other tribal centers) in order to test 

hypotheses and answer questions about past and future changing ecological conditions on the 

Olympic Peninsula. 

Strategy MH2: LOCAL AND CUSTOMARY KNOWLEDGE

Work with tribal and non-tribal partners to explore ways to gather, share and apply (when 

appropriate) traditional ecological knowledge, local and customary knowledge, and information 

obtained from cultural resource analyses.

Activity A: In collaboration with the Coastal Treaty Tribes, develop a program to survey and 

map “traditional cultural properties” in marine areas of interest to each tribe. This would 

include working with individual tribes to develop survey protocols to address the nature of 

properties surveyed, survey methodology, the sensitivity of survey data, disclosure and nondisclosure limitations, disposition of the data, and products derived from the data.

Activity B: Work with the Coastal Treaty Tribes, non-tribal communities and other partners 

to host scholarly and educational events that bring together natural science, social science 

and tribal knowledge experts to discuss pressing sanctuary management issues and ways in 

which traditional ecological knowledge could help to resolve those issues.

Activity C: Collect, analyze and share (as agreed) historical accounts and oral histories from 

historic (tribal and non-tribal) user groups of resources in the sanctuary, including 

community members, fishermen, divers, and others, in order to improve understanding of the 

role that maritime heritage played in the sanctuary‟s past and collect information relevant to 

current/future resource management in OCNMS. Ensure the information collected from 
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local communities as part of historical and cultural research projects is shared with these 

communities in a timely manner once projects are completed.

Strategy MH3: PUBLIC UNDERSTANDING OF TREATY RIGHTS

Work collaboratively with the Coastal Treaty Tribes to improve the public‟s understanding of 

treaty rights and how traditional lifeways form a vital connection between the past, the present 

and the future, with a focus on marine areas.

Activity A: Work with the Coastal Treaty Tribes to create protocols for developing, 

reviewing and communicating information about treaty rights and tribal cultures to sanctuary 

visitors, volunteers, staff, partners and local communities.

Activity B: Maintain ongoing communications with Coastal Treaty Tribes about 

opportunities to collaborate on events such as community festivals (Makah Days, Quileute 

Days, Chief Taholah Days, etc.), special events like Tribal Journeys and other 

commemorations or significant celebrations within tribal communities.

Activity C: Work collaboratively with the Coastal Treaty Tribes, Olympic National Park and 

other partners in the development of an OCNMS Long-Range Interpretive Plan that 

emphasizes appropriate messages and content relating to treaty rights, traditional and 

contemporary tribal communities, cultures and cultural values. 

 Identify opportunities for projects, facilities and program development with each 

Coastal Treaty Tribe (e.g., maps with American Indian place names, wayside exhibits 

on each of the tribes, new visitor centers, publications) to be located or distributed on 

tribal reservations and other locations.

 Identify opportunities for interpreting traditional culture and cultural values at the 

Olympic Coast Discovery Center.

 Continue to incorporate information about the Coastal Treaty Tribes into the standard 

training for sanctuary volunteers (including AC members).

Links to Other Action Plans: Collaborative and Coordinated Sanctuary Management, 

Community Outreach, K-12 Education, Higher Education, Visitor Services

Key Partners: Makah, Quileute and Hoh Tribes and the Quinault Indian Nation, Olympic Coast 

Intergovernmental Policy Council, Olympic National Park, Olympic Park Institute, OCNMS 

Advisory Council, Washington State Historic Preservation Office, Washington Department of 

Archeology and Historic Preservation, Makah Cultural and Research Center, Advisory Council 

on Historic Preservation, Puget Sound Maritime Historical Society, Washington State Historical 

Society, Washington Trust for Historic Preservation, Museum of History and Industry, 

commercial and sport fishermen, divers, local residents, historians and history organizations, 

Puget Sound Maritime Historical Society, Museum of History and Industry, Grays Harbor 

Historical Seaport Authority and Westport Maritime Museum
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E2. Socioeconomic Values of Resources in the Sanctuary Action Plan

Desired Outcome: Improved ecological, social, and economic resilience for the Olympic 

Peninsula.

Links to Goals: 

Goal G - Facilitate wise and sustainable use in the sanctuary to the extent that such uses are 

compatible with resource protection. 

Background:

Socioeconomic valuation of sanctuary resources is critical to sanctuary management. Social 

science data are used to examine the human dimension of marine resource management; to 

understand consumptive and non-consumptive human use patterns; to assess economic impacts 

of proposed activities; and to understand the attitudes, perception and beliefs of resource users. 

Each of these factors is not only directly relevant to the National Marine Sanctuaries Act 

(NMSA) and laws such as the National Environmental Policy Act (NEPA), but is also critical 

to devising policies and management strategies resulting in ecological, social, and economic 

resilience. Currently, very little socioeconomic or human use information exists for OCNMS. 

Thus, at this time OCNMS is not able to analyze socioeconomic effects of the sanctuary and 

sanctuary management as comprehensively as is needed, nor is it able to pursue an ecosystembased management (EBM) framework. EBM, to be effective, requires integrating both natural 

and social science data into ecosystem management decisions.

With improved information about the socioeconomic values of resources in the sanctuary, an 

improved understanding of what human uses are occurring in the sanctuary, and an improved 

understanding of what human uses might be proposed in the sanctuary, OCNMS will be better 

equipped to make sound sanctuary management decisions. Moreover, ecosystem-based 

management frameworks require management agencies to consider humans and human uses as 

part of ecosystems. To develop an effective ecosystem-based management framework, OCNMS 

management needs to develop a better understanding of socioeconomics and human uses in the 

sanctuary. Thus, this action plan is focused on socioeconomic and human use research and 

assessment and is intended to complement the Habitat Mapping and Classification Action Plan, 

Physical and Chemical Oceanography Action Plan, Populations, Communities and Ecosystems 

Action Plan, and Data Management, Sharing and Reporting Action Plan.

Strategy SV1: EXISTING SOCIOECONOMIC INFORMATION

Foster analysis and dissemination of existing socioeconomic data about Olympic Coast 

marine resources and human use patterns, including consumptive, non-consumptive and 

passive human use patterns.

Activity A: Identify key socioeconomic players in the sanctuary region and begin targeted 

outreach effort to communicate OCNMS goals, and its role as a facilitator, in regional 

socioeconomic characterization.

Activity B: Further develop the existing annotated bibliography of references relevant to 

socioeconomic valuation of marine resources on the Olympic Peninsula, and make this 

annotated bibliography widely available (post it on OCNMS website).
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Activity C: Review and summarize information on West-Coast wide efforts to collect 

data on human use patterns in the marine and coastal environment. 

Activity D: Make existing socioeconomic data widely available in user-friendly formats 

(such as GIS layers).

Strategy SV2: NEW SOCIOECONOMIC INFORMATION

Develop partnerships in order to collect, assemble, and analyze new information about human 

uses/activities occurring in the sanctuary and their socioeconomic values. 

Activity A: Submit a formal request to the Coastal Treaty Tribes expressing OCNMS‟

interest in partnering to assess and apply information on human use patterns and 

socioeconomic values.

Activity B: Work with the AC to form a working group to make recommendations on 

developing a common understanding of the human dimension of marine spatial planning and 

management in the OCNMS, and prioritizing socioeconomic data needs.

Activity C: Encourage the working group to initiate a small, joint (partnership driven) 

human use mapping project in order to develop an initial (general) socioeconomic 

characterization of the sanctuary region. This should be done using as many known 

resources as possible to minimize cost, time, and to build on or create new partnerships in 

the region. The socioeconomic characterization should address consumptive, nonconsumptive, and passive use.

Activity D: Develop a joint proposal for a more extensive socioeconomic study or 

expanded (more detailed) human use mapping project and pursue funding for this 

proposal. Look for opportunities to leverage capacity and share costs, e.g., through the 

West Coast Governor‟s agreement, the Sea Grant Program, and the state of Washington.

Links to Other Action Plans: Regional Ocean Planning, Populations, Communities and 

Ecosystems, Data Management, Sharing and Reporting, Collaborative and Coordinated 

Sanctuary Management, Community Involvement in Sanctuary Management, Community 

Outreach

Key Partners: Makah, Quileute, Hoh Tribes and Quinault Indian Nation, state of 

Washington, Olympic Coast Intergovernmental Policy Council, NMFS/NWFSC, Ecotrust and 

other NGOs, outer coast Marine Resource Committees, Olympic National Park, county 

Economic Development Councils and the Olympic Peninsula Tourism Commission
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5.3 PERFORMANCE MEASURES

Performance evaluation is an integral component of ONMS efforts to improve sanctuary 

management. The performance measures proposed here are designed to serve three purposes: 1) 

to better understand OCNMS‟ ability to meet its objectives; 2) to track OCNMS‟ success in 

addressing the issues identified in this management plan; and 3) to identify tangible examples of 

how OCNMS is contributing to both the performance targets developed for the Office of 

National Marine Sanctuaries and to achieving the mission of the NMSA. 

With implementation of the revised OCNMS management plan, OCNMS staff will monitor these 

performance measures over time, collecting data on progress towards their achievement. Results 

will be compiled for the AC, IPC, and other interested parties on an annual basis (see Sanctuary 

Operations Action Plan, Strategy OPS10). Accomplishments, as well as any inabilities to 

achieve outcomes will be reported, including potential strategies for mitigating shortfalls. This 

internal review represents one of the primary benefits of the performance evaluation process: the 

ability to provide feedback about why particular actions are or are not meeting stated targets and 

how they can be altered to do so. This process, where appropriate will mesh with other 

programmatic evaluation tools, such as the OCNMS Condition Report.

Eight performance measures (and associated outcomes) are listed below. Under each outcome 

and performance measure, a list of the relevant priority issues addressed is provided (see 

section 4.5). OCNMS may opt to modify or augment these performance measures in the future.

In some cases, it is difficult to measure the achievement of the priority issues (e.g., Improve 

Ocean Literacy, Achieve Effective Collaborative and Coordinated Sanctuary Management). In 

these cases, the performance measures provided are serving as proxies for difficult to measure 

outcomes.

OUTCOME 1: ONMS is recognized by its partners and constituents as an organization 

effectively seeking and considering information and opinions from external sources in its 

management and decision making.

Performance Measure 1: Maintain undiminished or improve ratings of OCNMS‟

effectiveness as evaluated by key partners and constituents through a brief annual 

survey (e.g., using a web survey tool) designed to assess their involvement in 

sanctuary management processes and the perceived effectiveness of this involvement 

in sanctuary management processes over the past year. This survey should use the 

same survey questions each year so that results can be compared over time.

Relevant Priority Management Need (s): Achieve Effective Collaborative and 

Coordinated Management

OUTCOME 2: Increased involvement of communities on the Olympic Peninsula in sanctuary 

management issues and ocean conservation.

Performance Measure 2: Demonstrate an increase in 1) individual public attendance at 

OCNMS-hosted public meetings and events (e.g., open houses, Advisory Council 

meetings); and 2) volunteer hours in OCNMS-led education, stewardship and 
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research efforts (e.g., Discovery Center, COASST, intertidal monitoring). This 

measure will be evaluated on an annual basis.

Relevant Priority Management Need(s): Achieve Effective Collaborative and 

Coordinated Management, Improve Ocean Literacy

OUTCOME 3: Increase the area of sanctuary seafloor where efforts to map, groundtruth, 

characterize or analyze habitats have been completed.

Performance Measure 3: Map, groundtruth, characterize, and/or analyze 300 square 

nautical miles of sanctuary seafloor each year. 

Relevant Priority Management Need(s): Conduct Collaborative Research, Assessments 

and Monitoring to Inform Ecosystem-Based Management

OUTCOME 4: ONMS will support collaborative and coordinated management through timely 

sharing of data collected by OCNMS.

Performance Measure 4: On an annual basis, track the progress made analyzing and 

distributing each data set that OCNMS collects. For each data set, report on 1) the 

date(s) the data were collected; 2) the expected annual and ultimate end product(s);

3) data sharing methods; 4) the time taken to analyze the data; 5) the time to 

disseminate the data; and 6) if necessary, when OCNMS anticipates completing a 

final analysis, report and dissemination. 

Relevant Priority Management Need(s): Conduct Collaborative Research, Assessments 

and Monitoring to Inform Ecosystem-Based Management

OUTCOME 5: Determine the effectiveness of sanctuary Ocean Literacy programs whose 

audiences include sanctuary users, students, teachers, volunteers and partner organizations.

Performance Measure 5: Track progress made during each year toward improving the 

quality of Ocean Literacy programs and their impacts on participants in improving 

their understanding of ocean processes and resources and enhancing their 

commitment to act as stewards.

Relevant Priority Management Need(s): Improve Ocean Literacy, Achieve Effective 

Collaborative and Coordinated Management

OUTCOME 6: Communicate the importance of the sanctuary and its unique resources, and the 

unique role of NOAA and Olympic Coast National Marine Sanctuary as a marine resource 

manager using a wide variety of media and methods to reach broad audiences.

Performance Measure 6: Track effort and outputs of outreach programs, using tools 

appropriate for the media, communication methods and audiences.

Relevant Priority Management Need(s): Achieve Effective Collaborative and 

Coordinated Sanctuary Management, Improve Ocean Literacy
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OUTCOME 7: ONMS is prepared for an oil or hazardous spill in or near the sanctuary.

Performance Measure 7: On an annual basis, 1) summarize and evaluate OCNMS 

participation in regional response planning efforts and spill drills; and 2) confirm that 

all OCNMS staff that have completed their assigned oil spill response training plan 

on an annual basis. 

Relevant Priority Management Need(s): Conserve Natural Resources in the Sanctuary

OUTCOME 8: The condition of water quality, habitat and living resources in the sanctuary is 

maintained or improved.

Performance Measure 8: Every five years, evaluate if the condition of sanctuary 

resources has been maintained or improved, as assessed through an OCNMS 

Condition Report. 

Relevant Priority Management Need(s): Conserve Natural Resources in the Sanctuary
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5.4 COST ESTIMATES AND TIMELINES

Cost estimates for each strategy were developed to provide a general sense of the scope and scale 

of the work being proposed in the FMP and the resources necessary to accomplish this work

(Table 4). These estimates are not proposed budgets. Estimates were developed based upon a 

series of assumptions that included a fixed cost of labor, and fixed estimates for travel time, 

supplies, printing, and other costs. These estimates do not account for inflation, staff merit pay 

increases, increases in cost of living, variable fuel and utility costs, etc., nor do these estimates 

differentiate between funds from the OCNMS base budget versus other funding sources (e.g., 

external grants, partnership with other agencies).

Table 4 Cost estimates associated with the action plan strategies (in thousands of dollars).

Strategies Year 1 Year 2 Year 3 Year 4 Year 5

CCM1 External Evaluation $8 $37 $4 $0 $0

CCM2 Coastal Treaty Tribes $55 $55 $55 $55 $55

CCM3 Olympic Coast Intergovernmental Policy 

Council $165 $165 $165 $165 $165

CCM4 State of Washington $9 $9 $9 $9 $9

CCM5 Department of Interior $8 $8 $8 $8 $8

CCM6 US Coast Guard $9 $9 $9 $9 $14

CCM7 US Navy $16 $9 $9 $9 $9

CCM8 NMFS $24 $24 $24 $24 $24

CCM9 Office of National Marine Sanctuaries $107 $107 $107 $107 $107

CCM10 Canadian Government $8 $8 $8 $8 $8

COM1 Advisory Council $51 $51 $51 $51 $51

COM2 Marine Resources Committees $13 $13 $13 $13 $13

COM3 Non-Governmental Organizations $17 $17 $17 $17 $17

OPS1 Vessel Infrastructure and Operations $148 $306 $306 $306 $306

OPS2 Facilities $211 $165 $165 $165 $165

OPS3 Annual Planning $40 $40 $40 $40 $40

OPS4 Safety Operations $12 $12 $12 $12 $12

OPS5 Staffing $104 $104 $104 $104 $104

OPS6 Volunteer Program $92 $92 $92 $92 $92

OPS7 Permitting and Consultations $48 $30 $30 $30 $30

OPS8 Voluntary Compliance $32 $16 $16 $16 $16

OPS9 Enforcement and Incident Response $18 $25 $18 $18 $18

OPS10 Management Plan Implementation Reporting $40 $40 $40 $40 $40

MAP1 Regional Coordination $11 $11 $11 $11 $11

MAP2 Seafloor Habitat Mapping $37 $218 $218 $218 $218
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Table 4 (continued) Cost estimates associated with the action plan strategies (in thousands of dollars).

Strategies Year 1 Year 2 Year 3 Year 4 Year 5

MAP3 Habitat Classification $42 $67 $67 $67 $67

MAP4 Mapping Products $30 $30 $56 $56 $56

OCEO1 Coastal Mooring Program $286 $286 $286 $286 $286

OCEO2 Hypoxia $31 $31 $31 $31 $31

OCEO3 Ocean Acidification $21 $21 $21 $21 $21

OCEO4 Harmful Algal Blooms $17 $17 $17 $17 $17

ECO1 Water Column Communities $0 $41 $41 $41 $41

ECO2 Intertidal $14 $28 $28 $28 $28

ECO3 Subtidal $10 $70 $70 $70 $70

ECO4 Benthic $337 $34 $337 $34 $337

ECO5 Fish $10 $10 $10 $10 $10

ECO6 Marine Birds $50 $78 $137 $82 $82

ECO7 Marine Mammals $13 $110 $225 $110 $90

ECO8 Stranding Networks $17 $17 $17 $17 $17

ECO9 Ecosystem Processes $23 $1 $71 $0 $0

DAT1 Data Quality Control and Management $7 $2 $2 $2 $2

DAT2 Data Distribution $33 $33 $33 $33 $33

DAT3 Adaptive Management $0 $13 $3 $3 $3

DAT4 Condition Report $0 $0 $0 $0 $36

ED1 K-12 Partnerships $52 $52 $52 $52 $52

ED2 Place-Based Education $118 $118 $118 $118 $118

ED3 Regional Initiatives $19 $19 $19 $19 $19

ED4 Technology $52 $52 $52 $52 $52

HED1 Internship Development $58 $58 $58 $58 $58

HED2 Volunteer Positions $7 $7 $7 $7 $7

HED3 College Partnerships $59 $59 $59 $59 $59

VISIT1 Visitor Experience $186 $186 $186 $186 $186

VISIT2 Long-Range Interpretive Plan $34 $34 $34 $34 $34

VISIT 3 New Technology $294 $294 $294 $294 $294

OUT1 Stewardship and Citizen Science $154 $154 $154 $154 $154

OUT2 Staff Presence on Outer Coast $27 $27 $27 $27 $27

OUT3 Community Events $74 $74 $74 $74 $74

OUT4 Community-Based Efforts $43 $43 $43 $43 $43
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Table 4 (continued) Cost estimates associated with the action plan strategies (in thousands of dollars).

Strategies Year 1 Year 2 Year 3 Year 4 Year 5

SPILL1 ATBA Management, Compliance and 

Monitoring $11 $20 $72 $36 $36

SPILL2 Regional Vessel Management Forums $12 $4 $4 $0 $0

SPILL3 Regional Planning and Training Exercises $39 $26 $21 $20 $26

SPILL4 Outer Coast Trustees Working Group $5 $5 $5 $5 $5

SPILL5 OCNMS Organizational Response Plan $3 $2 $2 $2 $2

SPILL6 Damage Survey and Assessment Protocols $5 $9 $20 $5 $5

CLIM1 Climate-Smart Sanctuary Program $75 $75 $75 $75 $75

CLIM2 Sanctuary as Sentinel Site $36 $36 $36 $36 $36

CLIM3 Resilient Ecosystems $73 $73 $73 $73 $73

CLIM4 Communicating Climate Change $101 $101 $101 $101 $101

MD1 Submerged or Floating Debris $8 $8 $8 $8 $8

MD2 Beach Debris $27 $27 $27 $27 $27

WD1 Outreach on Wildlife Disturbance $27 $27 $27 $27 $27

WD2 Overflight Restriction Zone $12 $0 $0 $0 $0

WD3 Marine Mammal Disturbance $0 $0 $12 $7 $0

WQP1 Vessel Discharges $6 $16 $0 $0 $0

WQP2 Contaminants $3 $2 $2 $2 $2

HP1 Threat Assessment and Mitigation $40 $0 $411 $16 $108

HP2 Habitats of Special Importance $37 $25 $34 $25 $34

HP3 Invasive Species $11 $13 $11 $11 $11

ROP1 Regional Ocean Planning $87 $95 $98 $98 $98

MH1 Cultural Resource Conservation $92 $92 $92 $92 $92

MH2 Local and Customary Knowledge $90 $90 $90 $90 $90

MH3 Public Understanding of Treaty Rights $28 $28 $28 $28 $28

SV1 Existing Socioeconomic Information $0 $39 $0 $0 $0

SV2 New Socioeconomic Information $0 $13 $21 $57 $0

TOTAL $4,228 $4,462 $5,431 $4,452 $4,819
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5.5 IMPLEMENTATION TABLE

The action plans in the FMP comprise a body of work that, to fully implement, would require 

resources well beyond what is currently available –and expected to be available – to ONMS. 

Cost estimates developed by OCNMS staff for each action plan indicate OCNMS would need 

an annual base budget ranging between $4.2 and $5.4 million (and a staff of approximately 40 

people) in order to accomplish all of the work in the action plans. OCNMS currently operates 

with an annual budget of around $1.5 million, not including in-kind support from other NOAA 

offices or grants from NOAA or other agencies and organizations. OCNMS staff is the 

equivalent of 16 full-time staff (including federal employees and contracted support services). 

The amount of in-kind support and grant funding OCNMS receives each year varies greatly. 

All of the strategies in the action plans are important in helping OCNMS meet its goals and 

objectives. However, given funding limitations, it was necessary to prioritize the strategies to 

show which are most likely to be implemented under various budget scenarios. In this way, 

OCNMS hopes to implement the management plan in as transparent a manner as possible. 

OCNMS staff worked with the OCNMS Advisory Council, the Olympic Coast 

Intergovernmental Policy Council and ONMS leadership in order to develop the implementation 

table that follows (Table 5), showing which strategies will be high, medium and low priorities 

for ONMS to complete under three different hypothetical budget scenarios:

 OCNMS remains level funded

 OCNMS receives a moderate increase in base funding

 OCNMS receives a significant increase in base funding

A considerable number of OCNMS projects are grant-funded. It is difficult to predict what grant 

funding will be available and how much of it ONMS will receive on an annual basis. Grant 

funds are typically geared toward one specific activity (and cannot be put toward other 

activities). ONMS will use the implementation table to guide staff efforts, but acknowledge that 

successful acquisition of grant funding for particular projects might also influence how ONMS 

allocates its staff resources year to year. 

5.5.1 Explanation of Implementation Table

Strategy Status

The status of the strategy indicates the amount of work completed on the strategy at the time of 

MPR. Certain strategies and activities have been partially or wholly implemented prior to or 

during the MPR process. Many of these represent ongoing initiatives that will continue. Other 

strategies are new as part of the updated management plan and have not been worked on at all. 

Funding Scenarios 1, 2 and 3

Implementation at various budget scenarios indicates the priority of a strategy or action plan and 

subsequent level of effort based on resources available. As stated previously, full 

implementation of the management plan exceeds the resources available to OCNMS, therefore 

requiring some prioritization of the strategies. As more resources become available (i.e., the 

budget grows), a greater level of implementation is possible. This table outlines to what extent 

implementation could occur with OCNMS‟ existing resources and how increases in resources 

would affect the amount of implementation possible for each strategy. 
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Table 5 OCNMS Management Plan Implementation Table

Table Legend

Strategy Status: 

 – Existing w/o significant 

modification 

  – Existing w/ significant 

modification 

 – New or future (Not yet 

implemented.) 

Implementation

Ranking: 

H – High

M – Medium

L – Low

Necessary Partnership 

Coordination: 

 – Not possible w/o partners 

  – Significant reliance on partners 

 – Little reliance on partners 

Primary Funding Sources: 

 – External (e.g. Grants) 

  – Internal and External 

 – Internal (increased budget)

 – Internal (base budget)

Action Plans

Strategy StatusLevel Funding: Scenario 1Moderate Increase: Scenario 2Substantial Increase: Scenario 3Partnership CoordinationInternal/external Funding Sources

Collaborative and Coordinated Sanctuary Management

CCM1 External Evaluation  L L M  

CCM2 Coastal Treaty Tribes  H H H  

CCM3 Olympic Coast IPC  H H H  

CCM4 Washington State  H H H  

CCM5 Department of Interior  H H H  

CCM6 US Coast Guard  H H H  

CCM7 US Navy  H H H  

CCM8 NMFS  M H H  

CCM9 Office of National Marine Sanctuaries  H H H  

CCM10 Canadian Government  L M M  

Community Involvement in Sanctuary Management 

COM1 Advisory Council  H H H  

COM2 Marine Resource Committees  M M M  

COM3 Non-government Organizations  H H H  

Sanctuary Operations

OPS1 Vessel Infrastructure and Operations  H H H  

OPS2 Facilities  H H H  

OPS3 Annual Planning  H H H  

OPS4 Safe Operations  H H H  

OPS5 Staffing  H H H  

OPS6 Volunteer Program  M H H  

OPS7 Permitting and Consultation  H H H  

OPS8 Voluntary Compliance  M M M  
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Table 5 (continued) OCNMS Management Plan Implementation Table

Action Plans

Strategy StatusLevel Funding: Scenario 1Moderate Increase: Scenario 2Substantial Increase: Scenario 3Partnership CoordinationInternal/external Funding Sources

Sanctuary Operations (continued)

OPS9 Enforcement and Incident Response  L L H  

OPS10 Implementation Reporting  H H H  

Habitat Mapping and Classification

MAP1 Regional Coordination  H H H  

MAP2 Seafloor Habitat Mapping  H H H  

MAP3 Habitat Classification  H H H  

MAP4 Mapping Products  H H H  

Physical and Chemical Oceanography

OCEO1 Coastal Mooring Program  H H H  

OCEO2 Hypoxia  M H H  

OCEO3 Ocean Acidification  H H H  

OCEO4 Harmful Algal Blooms  M M H  

Populations, Communities and Ecosystems

ECO1 Water Column Communities  L M H  

ECO2 Intertidal  M H H  

ECO3 Subtidal  L M H  

ECO4 Benthic  M H H  

ECO5 Fish  L L M  

ECO6 Marine Birds  M H H  

ECO7 Marine Mammals  M M H  

ECO8 Stranding Network  L L M  

ECO9 Ecosystem Processes  M M H  

Data Management, Sharing and Reporting

DATA1 Data Quality Control and 

Management  H H H  

DATA2 Data Distribution  H H H  

DATA3 Adaptive Management  L M H  

DATA4 Condition Report  M H H  

K-12 Education

ED1 K-12 Partnerships  H H H  
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Table 5 (continued) OCNMS Management Plan Implementation Table

Action Plans

Strategy StatusLevel Funding: Scenario 1Moderate Increase: Scenario 2Substantial Increase: Scenario 3Partnership CoordinationInternal/external Funding Sources

K-12 Education (continued)

ED2 Place-Based Education  M M H  

ED3 Regional Initiatives  L L M  

ED4 Using Technology  L L M  

Higher Education

HED1 Internship Development  L L M  

HED2 Volunteer Positions  L L M  

HED3 College Partnerships  L L L  

Visitor Services

VISIT1 Visitor Experience  L M H  

VISIT2 Long-Range Interpretive Plan  M M M  

VISIT 3 New Technology  L L L  

Community Outreach

OUT1 Stewardship and Citizen Science  L M M  

OUT2 Staff Presence on Outer Coast  L L M  

OUT3 Community Events  M M M  

OUT4 Community-Based Efforts  L M H  

Spills Prevention, Preparedness, Response and Restoration

SPILL1 ATBA Management, Compliance and 

Monitoring  H H H  

SPILL2 Regional Vessel Management 

Forums  L M H  

SPILL3 Regional Planning and Training 

Exercises  H H H  

SPILL4 Outer Coast Trustees Working Group  M M M  

SPILL5 OCNMS Organizational Response 

Plan  H H H  

SPILL6 Damage Survey and Assessment 

Protocols  H H H  

Climate Change

CLIM1 Climate Smart Sanctuary Program  L L M  

CLIM2 Sanctuary as Sentinel Site  M H H  

CLIM3 Resilient Ecosystems  L L M  

CLIM4 Communicating Climate Change  L L H  
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Table 5 (continued) OCNMS Management Plan Implementation Table

Action Plans

Strategy StatusLevel Funding: Scenario 1Moderate Increase: Scenario 2Substantial Increase: Scenario 3Partnership CoordinationInternal/external Funding Sources

Marine Debris

MD1 Assessment and Removal  H H H  

MD2 Mitigating Impacts  H H H  

Wildlife Disturbance

WD1 Outreach on Wildlife Disturbance  L L M  

WD2 Overflight Restriction Zone  L L L  

WD3 Marine Mammal Disturbance  M M M  

Water Quality

WQP1 Vessel Discharges  H H H  

WQP2 Contaminants  L L L  

Habitat Protection

HP1 Threat Assessment and Mitigation  M H H  

HP2 Habitats of Special Importance  H H H  

HP3 Invasive Species  M H H  

Regional Ocean Planning

ROP1 Regional Ocean Planning  L M H  

Maritime Heritage

MH1 Cultural Resource Conservation  L L M  

MH2 Local and Customary Knowledge  L L M  

MH3 Public Understanding of Treaty Rights  L L L  

Socioeconomic Values of Sanctuary Resources

SV1 Existing Socioeconomic Information  L L L  

SV2 New Socioeconomic Information  L L L  

Table Legend

Strategy Status: 

 – Existing w/o significant 

modification 

  – Existing w/ significant 

modification 

 – New or future (Not yet 

implemented.) 

Implementation 

Ranking: 

H – High

M – Medium

L – Low

Necessary Partnership 

Coordination: 

 – Not possible w/o partners 

  – Significant reliance on partners 

 – Little reliance on partners 

Primary Funding Sources: 

 – External (e.g. Grants) 

  – Internal and External 

 – Internal (increased budget)

 – Internal (base budget)
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Partnership Coordination

Implementation of most of the strategies in the FMP will require some input or coordination 

from partners, particularly the Coastal Treaty Tribes, other government agencies, research 

institutions, and NGOs. The table outlines the level of involvement expected from partners to 

achieve full implementation of each strategy. Many action plans and strategies are completely 

dependent on involvement from other agencies or dependent on research conducted by an 

outside institution. 

Internal/External Funding Sources

Funding for implementation of many strategies will require a mix of internal ONMS/OCNMS

funds as well as funding from external sources such as grants, or in-kind work from partner 

agencies. The table highlights the probable source of funding as either primarily internal (either 

at base of increased level), external or a mix of both. The table notes where it is anticipated the 

current OCNMS base budget would be sufficient to fund a strategy. The table also notes where a 

significant increase to OCNMS‟ base budget would be required to fund a strategy.

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6 AFFECTED ENVIRONMENT

The Affected Environment section describes the setting in which Olympic Coast National 

Marine Sanctuary‟s (OCNMS) management plan will be implemented. This section focuses on 

those resources most likely to be affected by specific actions and regulatory changes being 

considered in the management plan alternatives. OCNMS‟ original Final Environmental Impact 

Statement/Management Plan (NOAA 1993) also contains an in-depth affected environment 

section, which is incorporated here by reference. The more recent OCNMS Condition Report 

(ONMS 2008) is also incorporated by reference.

6.1 PHYSICAL SETTING

The physical setting of the sanctuary is the structural and dynamic foundation for its biological 

processes. Through the physical setting and the linkages between its geography, geology and 

oceanography, regional and large-scale ecosystem processes connect with and directly impact

local productivity and biodiversity patterns in the sanctuary. 

OCNMS spans 2,408 square nautical miles (8,259 square kilometers) of marine waters and the 

submerged lands thereunder off Washington state‟s Olympic Peninsula coast (Figure 3). In the 

north, OCNMS lies at the western entrance to the Strait of Juan de Fuca, a large waterway between 

United States and Canada that connects the Pacific Ocean with the Salish Sea. 

The sanctuary boundary, as defined in the OCNMS regulations (15 CFR 922, Subpart O), 

extends from Koitlah Point due north to the United States/Canada international boundary 

seaward to the 100 fathom isobath (approximately 180 meters depth). The seaward boundary of 

the sanctuary generally follows the 100 fathom isobath in a southerly direction to a point due 

west of the Copalis River, cutting across the heads of Nitinat, Juan de Fuca, and Quinault 

Canyons. The shoreward boundary of the sanctuary is the mean lower low water line when 

adjacent to American Indian lands and state lands. When adjacent to federally managed lands,

the sanctuary includes intertidal areas to the mean higher high water line. The coastal boundary 

of the sanctuary cuts across the mouths of but does not extend up rivers and streams.

Extending seaward 25 to 40 nautical miles (46 to 74 kilometers), the sanctuary covers much of 

the continental shelf and the heads of three major submarine canyons, in places reaching depths

of over 1,400 meters (750 fathoms or 4,500 feet). The sanctuary borders a largely undeveloped 

coastline, enhancing the protection provided by both the 104 kilometer-long (65 mile) coastal 

strip of Olympic National Park (ONP) that includes 87 kilometers (52 miles) of designated 

wilderness coast, as well as the approximately 600 offshore islands and emergent rocks within 

the Washington Maritime National Wildlife Refuge Complex. 

OCNMS lies in the northern portion of the Oregonian biogeographic province extending from 

Point Conception, California, to Cape Flattery, Washington (Airame et al. 2003). The province 

is characterized by a narrow continental shelf, mountainous shoreline, steep rocky headlands, 

sandy pocket beaches with sea stack islands, many small and a few large rivers, and small 
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Figure 3 Olympic Coast National Marine Sanctuary
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estuaries with barrier islands. The province is also noted as exhibiting the greatest volume of 

upwelling in North America. This nutrient-rich upwelling zone drives high primary productivity 

and supports a multitude of marine habitats. The sanctuary resides within the California Current 

System (CCS) and represents one of North America‟s most productive marine ecosystems.

6.1.1 Geography and Geology

The Olympic Coast is located at a tectonically active boundary known as the Cascadia 

Subduction Zone, where the edge of the North American continental plate meets and overrides 

the Juan de Fuca oceanic plate. The geologic activity in the area creates potential hazards such 

as earthquakes and associated submarine landslides, tsunamis and volcanic eruptions (McGregor 

and Offield 1986). 

The continental shelf extends 7 to 35 nautical miles (13 to 64 kilometers) from the outer coast of 

Washington and provides a relatively shallow coastal environment between the near shore and

the shelf break at about the 100-fathom (180-meter) contour. The majority of the sanctuary 

overlays the continental shelf. The shelf is composed primarily of soft sediment and glacial 

deposits of cobble, gravel and boulders, punctuated by rock outcrops. As described in 

section 6.2.4, the majority of the sanctuary seafloor has not yet been adequately mapped or 

characterized, so a full understanding of sediments and habitat distribution remains elusive

(Intelmann 2006). 

Sanctuary boundaries include portions of the Nitinat, Juan de Fuca, and Quinault submarine 

canyons that cut into the continental shelf along the western boundary of the sanctuary

(Figure 3). The Quinault Canyon is the deepest, descending to 1,420 meters (777 fathoms or 

4,660 feet) at its deepest point within the sanctuary. The Juan de Fuca Canyon Trough transects

the northern portion of the sanctuary angling toward the Strait of Juan de Fuca. These canyons 

are dynamic areas where massive submarine landslides occur on the steep side walls and canyon 

bottoms collect sediment deposited from above. These canyons also serve as conduits for dense, 

cold, nutrient-rich seawater that is pulled toward shore into sunlight, an upwelling that feeds 

surface productivity at the base of the food web. 

Broad beaches, dunes, and ridges dominate the coastline from Cape Disappointment, on the 

north side of the Columbia River, to the Hoh River, and rocky shores with smaller stretches of 

beach dominate to the north. Wave action has eroded the shoreline through time to form steep, 

tall cliffs at various places along the coast. Forested hills and sloping terraces are found near 

river mouths. In many places, a wave-cut platform, underwater with the tides, fronts the ocean 

where small islands, sea stacks, and rocks dot the platform's surface. 

6.1.2 Oceanography

The area around the sanctuary is characterized by distinct patterns in oceanographic circulation, 

winter storms, water flows influenced by topography and land-sea interactions. Large-scale 

processes are the predominant controlling factors for seasonal upwelling-downwelling 

fluctuations that produce a highly dynamic oceanographic environment. Large-scale movements 

of oceanic water masses, such as the California Current, which flows southward beyond the 

continental shelf, connect the sanctuary with the broader seascape of the eastern North Pacific 

Ocean and influence climate and marine productivity for the region. 
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A general characterization of ocean climate and behavior for the sanctuary region was developed 

recently from satellite imagery (Pirhalla et al. 2009; Figure 4). Winter months (November-midFebruary) are characterized by strong winds from the south (which forces downward transport of 

surface waters), heavy rainfall, and northward transport of the Columbia River discharge of fresh 

water and suspended materials. A spring transition period with variable conditions typically 

occurs in March. A spring/early summer bloom period occurs in April-June, when strengthened 

upwelling, increased surface water temperatures, and the Juan de Fuca outflow encourage 

increased plankton growth. During the summer/early fall period, offshore transport of surface 

waters, continued upwelling, increased light and temperature, with available nutrients out of the 

Juan de Fuca Strait combine to promote chlorophyll (phytoplankton) production along the entire 

Olympic Coast. A relaxation in upwelling, decrease in nutrients and chlorophyll, and shift 

toward northward flow of surface waters typify the fall transition period. 

Figure 4 Schematic of general physical factors controlling ocean surface response during January, May, 

July, and September (from Pirhalla et al. 2009)

On shore, the visible rise and fall of tides follow a mixed, semidiurnal pattern with two highwater and low-water phases per day. A mixed pattern means consecutive highs and lows have 

different tidal heights. The tidal range on the outer coast of Washington is large, averaging about 
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11.5 feet (3.5m) between high and low tides. Ocean surface water temperatures average about 

9°C (48°F) in winter and 15°C (58°F) in summer. 

6.1.3 Water Quality

Water quality within OCNMS is largely representative of natural ocean conditions, with 

relatively minor influence from human activities at sea and on land (ONMS 2008). By 

conventional measures, marine water quality within OCNMS is not notably compromised, in part 

because there have been few point sources of pollution in the vicinity, such as sewage outfalls or 

industrial discharge sites, and because there are no large industrial developments or large 

population centers adjacent to OCNMS. 

Stressors that may impact water quality in the sanctuary include hypoxic (low oxygen) 

conditions and harmful algal blooms. Results of increased water quality monitoring efforts in 

recent years indicate more frequent occurrence of hypoxic conditions as well as greater 

depression in oxygen levels than previously recorded (Chan et al. 2008; ONMS 2008), 

phenomena that have been tentatively linked to climate change impacts on ocean systems. 

Harmful algal blooms that impact wildlife and human populations are a naturally occurring 

phenomena subject to monitoring since the 1990s. There are limited data that define an 

increased frequency or geographical range of harmful algal blooms to human activities, such as 

nutrient inputs or factors related to climate change. A large-volume oil spill is generally 

considered the greatest threat to water quality in the sanctuary – a low-probability but highimpact threat. Another water quality concern is impact to nearshore habitats of increased 

sediment loading in rivers due to upland development, primarily road building and logging (see 

section 6.2.2).

Another source of pollutants with potentially negative water quality impacts is intentional 

discharges from vessels (e.g. sewage, graywater, ballast and bilge water). Vessel traffic volume 

through the sanctuary is high, as most vessels using the Strait of Juan de Fuca heading to the 

ports in Puget Sound and Vancouver, Canada, transit through OCNMS. Certain vessel classes, 

particularly cruise ships, are capable of generating wastewater quantities on par with small cities. 

The following sections evaluate vessel traffic in OCNMS and the quantity and types of vessel 

discharges in the context of existing regulations. 

6.1.3.1 Vessel Discharges

Wastewater is generated on all vessels through their normal operation. The quantity generated 

and the types of discharges vary depending on vessel size, function, and condition. The 

following sections describe types of discharges incidental to vessel operation, review the 

regulatory context for vessel discharges to marine areas, and provide an analysis of the potential 

annual inputs of specific discharges produced by the range of vessel types that use the sanctuary. 

The potential direct and indirect environmental effects these discharges have on water quality 

and marine life within the sanctuary are described in section 8. 

Sewage, also referred to as blackwater, is defined as human body wastes and the wastes from 

toilets and other receptacles intended to receive or retain body wastes 40 CFR 140.1(a). Sewage 

from vessels is generally more concentrated than sewage from land-based sources, as it is diluted 

with less water when flushed (e.g., 0.75 versus 1.5 - 5 gallons), and on many vessels sewage is 

not further diluted with graywater (NOAA 2008). Sewage generated on vessels should be 
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directed to a marine sanitation device (MSD). MSDs, which are described in more detail below,

may either a) hold untreated waste until it can be legally discharged into the ocean (e.g., beyond 

3 nmi from shore) or pumped to a land based treatment facility, or b) treat the sewage by 

reducing bacteria concentrations through chemical means and reducing the amount of solids by 

mechanical maceration or microbial decomposition prior to its discharge as treated effluent. In 

the past decade, some large passenger vessels, or cruise ships, that transit through the sanctuary 

have installed and utilized advanced wastewater treatment systems (AWTS) to treat sewage and, 

on some vessels, graywater. AWTS are a type of MSD that typically utilize a combination of 

biological and chemical treatment, and additional system components to produce an effluent with 

substantially better water quality than a traditional MSD.

Graywater originates from a variety of sources, such as showers, sinks, galleys, food waste 

pulpers and laundry and, if untreated, often contains pathogen and nutrient concentrations equal 

to or higher than untreated domestic sewage (EPA 2008a). Graywater on vessels may be 

discharged immediately upon generation, diverted to a wastewater treatment apparatus (e.g., 

MSD) or pumped to a long term holding tank. An individual vessel‟s ability to hold or treat 

wastewater can be highly variable, and capacities for various vessel types have not been 

accurately characterized in available literature.

Bilgewater is the mixture of fresh water and seawater, oily fluids, lubricants, cleaning agents, 

paint and metal shavings and other similar materials that accumulate in the lowest part of a 

vessel from a variety of different sources including the main and auxiliary engines; boilers, 

evaporators and related auxiliary systems; equipment and related components; and other 

mechanical and operational sources found throughout the machinery spaces of a vessel. 

Bilgewater may also originate from onboard spills, wash waters generated during the daily 

operation of a vessel, or waste water from operational sources (e.g., condensate from air coolers, 

etc.) that collect in the bilge (EPA 2008a).

Ballast water is water intentionally taken on board and stored in ballast tanks to provide stability 

under a range of vessel loading scenarios. Ballast water may contain a variety of marine 

organisms that can be transported and discharged outside their native range where they can pose 

a risk to local ecosystems. 

Sewage, graywater, and other vessel discharges are regulated through a complex framework of 

overlapping international treaties and standards, national laws and regulations, and local and 

area-specific rules. In general, the purpose of such rules and regulations is to protect water 

quality. The International Convention for the Prevention of Pollution from Ships (MARPOL) 

was created in 1973 to regulate marine pollution including oil, chemicals, harmful substances in 

package form, and sewage and garbage that enter the marine environment from either accidental 

or operational causes. State and federal laws also regulate certain types of discharges from 

vessels under authority of the Federal Water Pollution Control Act, also informally called the 

Clean Water Act (CWA; 33 U.S.C.1251 et seq.), and other regulations. 

In the U.S., all non-recreational vessels 79 feet or greater in length may not discharge substances 

to marine waters without operating under a National Pollutant Discharge and Elimination System

vessel general permit (VGP). This permit allows and sets effluent limits for most discharges 

incidental to the operation of large vessels, including desk wash, bilgewater, ballast water, boiler 
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blowdown, chain locker effluent, elevator pit effluent, graywater, distillation and reverse osmosis 

brine, and more. Sewage discharges, however, are not covered by the VGP but are subject to the 

applicable local, state, federal jurisdictional regulations. The geographic extent of coverage of 

the VGP extends to 3 miles from shore, so the guidance and regulations therein do not pertain to 

the majority of the sanctuary. However, the VGP does recognize national marine sanctuaries as 

“waters federally protected wholly or in part for conservation purposes” and includes more 

restrictive provisions addressing various wastewater sources that apply in OCNMS and other 

national marine sanctuaries. Fishing and commercial vessels under 79 feet long are exempt from 

VGP coverage based on a moratorium extending through December 2013. Certain discharges 

from these vessels, such as ballast water, are not exempt even during the moratorium. 

Recreational vessels and all military vessels are exempt from the VGP permanently, or until the 

law changes.

The OCNMS boundary lies between 25 and 40 nmi from shore, with approximately 83% of the 

sanctuary‟s area beyond 3 nmi from shore. Thus, Washington State regulations and the VGP 

apply in near shore waters that comprise less than one fifth of the sanctuary. As outlined below, 

under current federal, state, and local regulations and agreements, treated or untreated sewage 

and graywater discharges by recreational and commercial vessels are allowed under current 

regulations throughout a large portion of the sanctuary. 

Regulatory Context for Vessel Discharges - Sewage

Internationally, sewage discharges are regulated under the authority of Annex IV of MARPOL, 

adopted in 2003. These regulations and revisions now apply to all vessels over 400 gross tons 

(GT) or certified to carry more than 15 persons, require an approved sewage treatment system, 

and prohibit discharge of treated sewage within three nmi from shore and untreated sewage 

within 12 nmi from shore (IMO 2002). Although the United States did not ratify MARPOL 

Annex IV, it does apply to most foreign flagged ships. In 2009, 74% of the vessels included in 

the analysis of sewage discharges below (Table 6) were foreign flagged. U.S. flagged vessels are 

not subject to MARPOL Annex IV regulations, but they must comply with the CWA, VGP or 

other state laws when operating in waters within 3 miles of shore. 

The U.S. regulates sewage discharges from all vessels under the CWA. Collectively, CWA 

Section 312 and its implementing regulations require all vessels with toilet facilities to have 

operable MSDs, allow discharges of treated sewage any distance from shore (except where a no 

discharge zone has been established), and allow discharges of both untreated and treated sewage 

beyond three miles from shore or at land based pump-out facilities. CWA Section 312 requires 

federal performance standards for MSDs, which have been described by the U.S. Coast Guard 

(33 CFR Part 159). Standards for discharge from MSDs were developed by the U.S. EPA and 

are described in 40 CFR Part 140. Larger vessels, such as cruise ships, may combine sewage 

(blackwater) with graywater prior to treatment and discharge. Combined discharges of this sort 

are subject to graywater effluent limits set forth in the VGP rather than MSD (sewage) effluent 

standards. 

Under the authority of the CWA states may establish No Discharge Zones (NDZs) in which the 

discharge of sewage from vessels is prohibited if any of the following three criteria are met:
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1. The state determines that the water body requires greater environmental protection, and 

EPA finds that adequate pump-out facilities are available (commonly known as a 

312(f)(3) NDZ).

2. EPA, upon application by the state, determines that the protection and enhancement of 

the water body requires establishment of an NDZ even if pump-out facilities are not 

reasonably available (commonly known as a 312(f)(4)(A) NDZ).

3. EPA, upon application by a state, will, by regulation, prohibit the discharge of sewage 

from vessels within a drinking water intake zone (commonly known as a 312(f)(4)(B) 

NDZ). 

Table 6 Potential gallons of sewage discharges in OCNMS in 2009

Vessel 

Classification

Number of 

Transits 

through 

OCNMS

Number of 

People 

Aboard

Vessel 

Days in 

OCNMS

Sewage

Discharge 

Volume

(low) a

Sewage 

Discharge 

Volume

(avg) b

Sewage 

Discharge 

Volume

(high) c

Percent 

Contribution

Commercial 

Fishing Vessel 3,006 4 1,577 34,694 94,620 189,240 9.5%

Charter Fishing 

Vessel 1,148 11 287 16,732 45,633 91,266 4.6%

Recreational 

Fishing Vessel 10,351 3 2,588 39,851 108,686 217,371 10.9%

Commercial Vessel 

< 300GT 249 4 34 752 2,052 4,104 0.2%

Commercial Vessel

300-1599 GT 65 12 10 653 1,782 3,564 0.2%

Commercial Vessel

> 1600 GT 4,272 15 280 23,117 63,045 126,090 6.3%

Passenger Vessel

< 300 GT 14 300 1 1,320 3,600 7,200 0.4%

Passenger Vessel

300-1599 GT 9 500 1 2,200 6,000 12,000 0.6%

Passenger Vessel

> 1600 GT 280 2,921 14 231,343 630,936 1,261,872 63.3%

Public Vessel

< 300 GT 16 2 2 23 63 126 0.0%

Public Vessel

300-1599 GT 75 8 10 458 1,248 2,496 0.1%

Public Vessel

> 1600 GT 157 15 17 1,427 3,893 7,785 0.4%

Tank Vessel 1,401 15 145 11,996 32,715 65,430 3.3%

Tug with tank 

barge 189 4 35 779 2,124 4,248 0.2%

TOTAL 21,232 N/A 5,003 365,345 996,396 1,992,792 100%

a. Low sewage discharge volume estimate is based on a waste generation rate of 5.5 gallons/person/day.

b. The average sewage discharge volume estimate is based on a waste generation rate of 15 gallons/person/day.

c. The maximum sewage generation rate is based on a 30 gallon/person/day.
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Historically, NDZs have not distinguished between vessel categories and apply to all vessels 

regardless of size or purpose. However, the EPA and the State of California are in the process of 

establishing a NDZ for the length of the California coast, based on criteria 2 (above), which will 

prohibit sewage discharge, whether treated or not, and will apply only to commercial passenger 

vessels 300 GRT or larger, and commercial vessels larger than 300 GRT with two or more days 

of sewage holding capacity. The proposed rule (40 CFR 140) was signed in 2010 and 

finalization of the regulation is pending. 

In Washington State waters, vessel discharges must meet state water quality standards (per 

Chapter 90.48 RCW and Chapter 173-201A WAC), yet most traditional MSDs and, in some 

cases, AWTS do not meet those standards. Thus, Washington State guides vessels to onshore 

pumpout treatment facilities or to withhold discharges until outside of state waters via general 

outreach measures or by documented guidance, such as agreements. 

In Washington State, cruise ships are subject to the same regulations as other large vessels. 

However, in 2004, a memorandum of understanding (MOU) was developed between the North

West & Canada Cruise Association (NWCCA), Port of Seattle and the Washington Department 

of Ecology (WDE), prohibiting sewage and graywater discharges within state waters (which 

extend north to the border with Canada in the Strait of Juan de Fuca and 3 nautical miles offshore 

from the Olympic Peninsula) from cruise ships not utilizing AWTS. This MOU is a voluntary 

agreement with NWCCA member organizations. Cruise ships utilizing AWTS may attain 

permission to discharge in Washington State waters if effluent limits and monitoring constraints 

of the NWCCA MOU are met. Cruise ships without AWTS or without approval to discharge are 

not allowed to discharge treated wastewater and all untreated wastewater is prohibited in state 

waters. In 2007, this MOU was modified to eliminate any discharge into waters of OCNMS of 

residual solids from either a Type II MSD or an AWTS (WDE 2009). However, there are no 

provisions in the NWCCA MOU related to discharge of treated sewage from MSDs or AWTS in 

OCNMS waters. In 2010, OCNMS proposed amendment of the MOU to prohibit all discharges 

from cruise ships into waters of the sanctuary, but this amendment was opposed by the cruise 

ship industry, which wanted to avoid complicating the MOU with multiple boundaries subject to 

differing MOU provisions. In 2010, representatives from the NWCCA confirmed that affiliated 

vessels currently avoid all wastewater discharges in OCNMS, a practice consistent with 

regulatory requirements in national marine sanctuaries in California (John Hansen, former 

President, NWCCA).

Cruise ships, as described in the discharge analysis below, have the potential to generate and 

discharge greater quantities of sewage and graywater than other vessel categories. In light of 

this fact, various jurisdictions have adopted regulatory and voluntary measures to mitigate 

environmental impacts of sewage discharges from cruise ships. In 2001, The Alaska Department 

of Environmental Conservation (ADEC) developed the Commercial Passenger Vessel 

Environmental Compliance Program under Alaska Statute 46.03.460. This program set effluent 

limits and sampling requirements for the discharge of blackwater and graywater from cruise 

ships. Since then, additional measures have been instituted by ADEC to further regulate 

discharges from cruise ships. Beginning in 2003 all blackwater and graywater discharges from 

cruise ships in Alaska were subject to stricter water quality standards, with a requirement for 

treatment by an approved AWTS. Cruise ships discharging treated sewage into Alaska state 
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waters are now required to operate under a State vessel general permit, which sets stringent 

effluent limits for sewage and graywater discharges (ADEC 2010b). 

There is a precedent for limiting sewage discharges from large vessels (greater than 300 GT), 

and in some cases explicitly cruise ships, from national marine sanctuaries or other waters 

protected for conservation purposes on the West Coast. The four national marine sanctuaries 

off California, Cordell Bank, Gulf of the Farallones, Monterey Bay, and Channel Islands, have 

instituted rules prohibiting vessels 300 GT or larger from discharging treated or untreated 

sewage regardless of sanitation device type (15 CFR 922 Subparts G, H, K, and M). Cruise ship 

discharges are expressly prohibited within Glacier Bay National Park through the U.S. National 

Park Service‟s concession contract with large cruise ships for entry into the park. 

Existing OCNMS regulations allow for MSD-treated sewage discharges from all vessel types, 

although discharge of untreated sewage is prohibited under the CWA in state waters. In 

addition, the Area to be Avoided (ATBA), a voluntary vessel traffic routing measure that applies 

to vessels above 1600 GT and those carrying petroleum and hazardous materials as cargo, 

indirectly prevents sewage and other vessel wastewater discharges from approximately 70% of 

OCNMS. The ATBA routes these vessels 25 nmi off the coast except at the approach to the 

Strait of Juan de Fuca (Figure 8; see section 6.4.2). Compliance with the ATBA is routinely 

monitored, and compliance rates have been consistently near 98%. Thus, the majority of the 

discharges from large commercial vessels estimated in Table 6 and Table 7 would take place in 

the 30% of the sanctuary that is outside the ATBA.

Marine Sanitation Devices

The CWA requires that any vessel with installed toilet facilities must have an operable MSD. 

Three general types of MSDs are available and in use. Type I MSDs rely on maceration and 

chemical disinfection for treatment of the waste prior to its discharge into the water, and are only 

legal in vessels under 65 feet in length (EPA 2010a). Type II MSDs utilize aeration and aerobic 

bacteria in addition to maceration for the breakdown of solids. As with Type I MSDs, the waste 

is chemically disinfected, typically with chlorine, ammonia or formaldehyde, prior to discharge. 

Type II MSDs are legal in any size class of vessel, and there are a variety of different types 

(EPA 2008b). Type III MSDs are storage tanks, may contain deodorizers and other chemicals, 

predominantly chlorine, and are used to retain waste until it can be disposed of at an appropriate 

pump-out facility or at sea. Most MSDs do not have the same nutrient removal capability as 

land-based treatment plants. Thus, even treated vessel wastewater can have elevated nutrient 

concentrations. 

Advanced wastewater treatment systems (AWTS) are a complex form of Type II MSD that meet 

a higher standards and testing regime as set out in federal law, and utilize techniques such as 

reverse osmosis, ultrafiltration and ultra violet (UV) sterilization to provide more effective 

treatment. AWTS have been installed and operational on more than half (9 of 15) larger 

passenger vessels that will transit the sanctuary in 2011 and on these vessels blackwater and 

graywater are combined (WDE 2011). AWTS have been installed on some of the other 

passenger vessels; however, due to equipment and operating challenges, they are not functioning 

properly and are not being used (Amy Jankowaic, WDE, personal communication). These 

vessels are therefore currently using traditional (Type II) MSDs. The treatment capabilities of 

AWTS for certain constituents (e.g. nutrients and metals) vary by design and manufacturer, but 
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overall, the performance of these units far surpasses the performance of traditional (Type II) 

MSDs if functioning properly. For example, suspended solids, residual chlorine, and fecal 

coliform concentrations in AWTS effluent are typically zero (ADEC 2010b). Because of the 

varying treatment capabilities of the different AWTS systems, ADEC established technology 

based effluent limits, similar to the methodology used by the EPA for issuing municipal 

wastewater permits. The NWCCA MOU specifies effluent limits for conventional pollutants, 

including organics, solids, pH, fecal coliform and residual chlorine for discharges from AWTS, 

and does not include limits for ammonia, metals or other pollutants. The MOU also does not

differentiate between AWTS types. 

Table 7 Potential gallons of graywater discharges in OCNMS in 2009

Vessel 

Classification

Number of 

Transits 

through 

OCNMS

Number 

of People 

Aboard

Vessel 

Days in 

OCNMS

Graywater 

Discharge 

Volume

(low) a

Graywater 

Discharge 

Volume

(avg.) b

Graywater 

Discharge 

Volume

(high) c

Percent 

Contribution

Commercial Fishing 

Vessel 3,006 4 1,577 227,088 422,636 750,652 11.2%

Charter Fishing 

Vessel 1,148 11 287 Graywater potential discharges were not estimated for charter 

and recreational fishing vessels, due to uncertainties about 

vessel equipment and practices.

Recreational 

Fishing Vessel 10,351 3 2,588 

Commercial Vessel

< 300GT 249 4 34 4,925 9,166 16,279 0.2%

Commercial Vessel 

300-1599 GT 65 12 10 4,277 7,960 14,137 0.2%

Commercial Vessel

> 1600 GT 4,272 15 280 151,308 281,601 500,157 7.5%

Passenger Vessel

< 300 GT 14 300 1 8,640 16,080 28,560 0.4%

Passenger Vessel 

300-1599 GT 9 500 1 14,400 26,800 47,600 0.7%

Passenger Vessel

> 1600 GT 280 2,921 14 1,514,246 2,818,181 5,005,426 74.9%

Public Vessel

< 300 GT 16 2 2 151 281 500 0.0%

Public Vessel

300-1599 GT 75 8 10 2,995 5,574 9,901 0.1%

Public Vessel

> 1600 GT 157 15 17 9,342 17,387 30,881 0.5%

Tank Vessel 1,401 15 145 78,516 146,127 259,539 3.9%

Tug with tank barge 189 4 35 5,098 9,487 16,850 0.3%

TOTAL 21,232 N/A 5,003 2,020,986 3,761,280 6,680,482 100%

a. Low graywater discharge volume estimate is based on a waste generation rate of 36 gallons/person/day.

b. The graywater average discharge volume estimate is based on a waste generation rate of 67 gallons/person/day.

c. The maximum graywater generation rate is based on a 119 gallon/person/day.
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Regulatory Context for Vessel Discharges - Graywater

Currently, there are no existing or proposed international regulations regarding graywater. In 

the U.S., graywater discharge from ships is regulated under the VGP. The VGP graywater 

rules include guidance to minimize production and discharge while in port, include different 

requirements for medium (100-499 berths) and large (500 or more berths) cruise ships, prohibit 

discharge within 3 miles of shore within a national marine sanctuary for vessels with graywater 

storage capacity, allow for discharge from vessels greater than 400 gross tons if the effluent 

meets treatment standards or if the vessel is underway more than 1 nmi of shore, and include 

special considerations for nutrient impaired waters. Treated graywater must meet strict standards 

for fecal coliform and chlorine concentrations that far exceed standards for traditional MSD 

effluent (EPA 2008b). The VGP does not have treatment requirements for large vessels when 

discharging underway (i.e., greater than 1 nmi from shore and when traveling faster than 

6 knots). 

Current OCNMS regulations allow discharge of graywater as “water generated by routine vessel 

operations”. Under voluntary measures defined in the MOU between the North West and 

Canada Cruise Association, Port of Seattle, and WDE, cruise ships represented by the association 

will not discharge graywater (treated or untreated) in Washington State waters, with an exception 

for discharge of treated graywater from vessels with AWTS. 

Regulatory Context for Vessel Discharges - Ballast Water

The discharge rate and constituent concentrations of ballast water from vessels will vary by 

vessel type, ballast tank capacity, and type of deballasting equipment. Volumes of ballast 

water discharged are large and can be several hundred or thousand cubic meters of water. For 

instance, passenger vessels have an average ballast capacity of about 2,600 cubic meters (about 

686,850 gallons), and ultra large crude carriers have an average ballast capacity of about 

93,000 cubic meters (about 24,568,000 gallons) (EPA 2008b). Ballast water exchange volume 

for each of the vessel classes was not computed for further analysis, as the risk that ballast water 

poses to the sanctuary has more to do with the manner (i.e., location) that ballast water is 

exchanged rather than the volume of exchanges. 

Ballast water from ships has been a major source of non-native species introduction around the 

world. The current best practice for managing ballast water is an at-sea exchange of ballast 

water, wherein coastal water taken at or near a port is replaced with less biologically productive 

open oceanic water. Fewer organisms are present in open ocean water than in coastal waters. 

This practice is not 100% effective as some non-native organisms can survive until discharged in 

a foreign port or coastal area (NOAA 2008). 

OCNMS is partially protected from the introduction of non-native species through existing 

federal, state and international regulations associated with ballast water management. In July 

2004, the U.S. Coast Guard published a final rule changing the nation‟s voluntary Ballast Water 

Management Program to a mandatory one requiring all vessels equipped with ballast water tanks 

and bound for ports or places of the United States to conduct a mid-ocean ballast water exchange 

(more than 200 nmi offshore), retain their ballast water onboard, or use an alternative, 

environmentally sound, ballast water management method approved by the USCG (69 FR 

44952). The state of Washington‟s regulations have this same requirement for mid-ocean 

exchange that applies to vessels 300 gross tons or larger that have traveled outside the economic 
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exclusion zone (EEZ). For vessels that do not leave the EEZ, ballast water exchanges must be 

conducted beyond 50 nmi from shore (WDFW 2009). These measures substantially reduce the 

risk of invasive species introductions into sanctuary waters. Washington State ballast water 

management regulations only apply to vessels bound for American ports; however, Canada has 

adopted the 2004 IMO International Convention for the Control and Management of Ship‟s 

Ballast Water and Sediment (Transport Canada 2010). This agreement provides the same 

restrictions as Washington State regulations, and all ships calling on Canadian ports are required 

to comply (IMO 2004). The VGP requires vessels to avoid discharge of ballast waters within 

3 nmi of shore within a national marine sanctuary. In summary, these regulations and 

agreements prohibit discharge of all ballast water that originates from distant nearshore areas but 

allow discharge into the sanctuary beyond 3 nmi from shore and other Washington State waters 

of ballast water that originates from an open ocean exchange. 

Regulatory Context for Vessel Discharges – Bilgewater

Bilgewater is the mixture of fresh water and seawater, oily fluids, lubricants, cleaning fluids and 

other wastes that accumulate in the bilge, or lowest part of a vessel hull, from a variety sources 

including leaks, engines and other parts of the propulsion system and other mechanical and 

operation sources found throughout the vessel (EPA 2008a). All vessels accumulate bilgewater 

through their normal operation, but the generation rates depend on a variety of factors including 

hull integrity, vessel size, engine room design, preventative maintenance and the age of the 

vessel (EPA 2008a; EPA 2010b). In addition to oil and grease, bilgewater may also contain a 

variety of other solid and liquid contaminants, such as rags, metal shavings, soaps, detergents, 

dispersants and degreasers (EPA 2008a). Estimates of bilgewater discharges to the sanctuary are 

not available for most classes of vessels. Data for bilgewater generation from cruise ships were 

available, with an estimated volume of 25,000 gallons produced per week (3,500 gallons per 

day) on vessels with 3000 passenger/crew capacity (EPA 2008b). 

Several national and international regulations govern allowable discharges of bilgewater in an 

effort to reduce oil contamination of the oceans. These regulations require ships to have in 

operation oily-water separating equipment, and discharges may not exceed 15 parts per million 

oil. The VGP prohibits discharge of treated or untreated bilgewater from vessels 400 gross tons 

or more within 3 mi of shore in a national marine sanctuary. OCNMS regulations prohibit all 

discharge of oily waste from bilge pumping. Because sanctuary regulations do not specify a 

limit, this has been interpreted by ONMS as prohibiting any detectable amount of oil as 

evidenced by a visible sheen (EPA 2008a; 73 FR 70488). Under current OCNMS regulations,

discharge of bilgewater not leaving a visible sheen is allowed. 

Regulatory Context for Vessel Discharges – Other Discharges

Several discharges incidental to the normal operation of a vessel covered by the exclusion in 

40 CFR 122.3 are also eligible for coverage under the VGP. Below is a list of these discharges:

 Anti-fouling hull coatings

 Boiler blow-down

 Cathodic protection

 Chain locker effluent (anchor wash)

 Controllable pitch propeller and thruster hydraulic fluid and other oil to sea interfaces...

 Distillation and reverse osmosis brine
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 Elevator pit effluent

 Firemain systems

 Freshwater layup

 Gas turbine water wash

 Motor gasoline and compensating discharge

 Non-oily machinery wastewater,

 Refrigeration and air condensate discharge

 Seawater cooling overboard discharge (including non-contact engine cooling water, 

hydraulic 

 System cooling water, refrigeration cooling water

 Seawater piping biofouling prevention

 Boat engine wet exhaust

 Sonar dome discharge

 Underwater ship husbandry discharges

 Welldeck discharges

The volume and contents of the above listed discharges are presumed to be similar for similarly 

sized vessels and are not dependent on the vessel purpose (EPA 2008b). With the exception of 

graywater and pool and spa discharges from cruise ships, oily discharges, including oily 

mixtures, and residual biocide limits from vessels utilizing experimental ballast water treatment 

systems, numeric effluent limitations are not feasible to calculate for vessel discharges in VGP. 

Therefore, the EPA establishes effluent limits based on Best Practical Control Technology 

Currently Available (BPT) or Best Available Technology (BAT) rather than specifying specific 

effluent limits. Existing OCNMS regulations include an exception to the discharge prohibition 

for water generated by routine vessel operations, which includes those mentioned above.

Discharge Volume Estimation Methods

In order to evaluate the potential for water quality impacts to the sanctuary from vessel 

discharges, estimates of discharges generated by classes of vessels were calculated based on the 

time a given vessel class spent in the sanctuary during 2009 (vessel days) and published waste 

generation rates. Vessel days for a given vessel class was calculated by determining the 

cumulative time individual vessels of a specified class were within sanctuary boundaries. 

Sewage generation rates used for estimates provided in Table 6 were based on information from 

MSD manufacturers. Additional details regarding discharge volume estimation methods can be 

found in Appendix K.

Although many vessels do have wastewater holding tanks and may not discharge while operating 

in the sanctuary, it is not possible to accurately characterize the times, locations, and volumes 

of sewage and other discharges that actually occur in the sanctuary. For the purpose of this 

document, analysis was conducted on the potential to discharge to sanctuary waters based on 

estimated waste generation rates and residence time (vessel days) in the sanctuary. Potential 

discharge volumes are proportional to waste generation rates, which can be considered a worstcase scenario because discharges may or may not occur in waters of the sanctuary. One factor 

influencing wastewater discharges into waters of the sanctuary is average transit time. Large, 

commercial vessels complying with the ATBA (vessels >1,600 GT, and tugs with tank barges) 

would transit waters of the sanctuary only at the western approach to the Strait of Juan de Fuca 
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(Figure 8). In OCNMS regulations, cruise ships are defined as vessels with 250 or more 

passenger berths for hire. However, the following analysis is based on categories of vessels 

used by the vessel traffic system under which cruise ships are classified as passenger vessels 

>1,600 GT. For cruise ships, the average transit time in OCNMS is 74 minutes (1.2 hours; Table

11). By comparison, commercial vessels of various sizes average about 170 minutes in 

OCNMS, and public vessels and tank vessels average roughly 200 minutes in OCNMS (Table

11). While the estimated potential wastewater discharge volumes from all ships represent a 

threat to water quality, actual discharges may not occur or impact OCNMS water quality because 

transit times provide relatively short windows of opportunity for wastewater discharges to occur 

in OCNMS.

Cruise Ship Wastewater Discharges

The cruise ship industry is rapidly expanding in the Pacific Northwest, with the number of 

passengers through the Port of Seattle increasing from 120,000 to nearly 900,000 between 2000 

and 2009 (WDE 2010). In 2009, there were 280 cruise ship transits in OCNMS (VEAT 2009), 

representing 14 vessel days in sanctuary waters (see Passenger Vessels >1,600 GT in Table 6). 

If the passenger numbers on these cruises continue to increase, there will be a proportional 

increase in wastewater generation. The largest cruise ships are capable of carrying a combined 

population of about 4,000 passengers and crew (WDE 2009). 

Estimates of potential wastewater discharges from cruise ships (i.e., passenger vessels 

>1,600 GT) presented in Table 6 and Table 7 assume an average of 2,921 passengers and crew 

on board, the average reported for cruise ships using the Port of Seattle (WDE 2009). Despite 

cruise ships spending relatively little cumulative time in the sanctuary compared to other large 

vessel classes, the potential sewage discharge volume from cruise ships is higher than that 

estimated for all other large vessel classes and represents 63% of all potential sewage discharges 

in the sanctuary (Table 6). The average graywater generation rate of 67 gallons/person/day 

(EPA 2008a) could potentially result in millions of gallons of graywater discharged from cruise 

ships into the sanctuary annually, which dwarfs potential discharges from all other vessel classes 

and represents 75% of the all potential graywater discharges in the sanctuary (Table 7).

The quality of potential blackwater and graywater discharges from cruise ships, hence risk to 

sanctuary resources, is difficult to characterize based on existing data. Data from the 2011 

Washington Department of Ecology discharge status report (WDE 2011) indicate that 15 cruise 

ships are scheduled to call on the Port of Seattle for a total of 195 port calls, corresponding to 

390 transits through or near the sanctuary. Whereas more than half (9 of 15) of the cruise ships 

calling on the Port of Seattle have installed AWTS for blackwater and/or graywater treatment, 

35% of the port calls will be completed by vessels that have traditional MSDs for blackwater 

treatment and no treatment system for graywater (WDE 2011). Furthermore, only 2 of the 15 

vessels have met effluent standards and monitoring requirements set forth in the NWCCA MOU

and have requested and gained authority to discharge while underway in Washington state waters

(WDE 2011). Only vessels that are authorized to discharge per the NWCCA MOU are required 

to monitor and submit results, and are required to submit documentation that they have 24 hour 

continuous monitoring for treatment system performance and disinfection, as well as the ability 

and procedures to automatically shut down if continuous monitoring of treated effluent indicates 

high turbidity or a disinfection system upset. Therefore, it cannot be assured that the AWTS 

performance controls or effluent monitoring otherwise required by the VGP or NWCCA MOU 
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are performed on most ships. Some vessels only operate their AWTS when in certain areas 

where it is required and use a traditional MSD for other discharges. Given the uncertainties in 

the type and performance (operational performance and frequency of system upset) of the 

treatment systems installed on board cruise ships, it is impossible to accurately estimate the 

quantity (i.e., mass load) of contaminants potentially deposited into the sanctuary.

In open waters of the sanctuary, concern for localized and acute effects of wastewater discharges 

from a cruise ship in transit is reduced by the free exchange of waters and dilution that occurs in 

the ship‟s wake. Rapid dilution of wastewater (blackwater and graywater) discharged from 

MSDs has been documented to occur when discharged from cruise ships under way. Loehr et al.

(2006) showed that under a worst case scenario (i.e., lowest dilution factor possible and high 

discharge rate) that the dilution factor for discharges from large cruise ships is 1:50,000 when 

traveling at 6 knots discharging at 200 cubic meters per hour. Loehr et al. (2006) further 

documented, based on sampled effluent concentrations from 21 cruise ships using traditional 

MSDs, that priority pollutants (metals and organics) were rapidly diluted to many times below 

Alaska water quality standards. In Washington State, mixing zones have not been applied to 

cruise ship discharges. Mixing zones are typically established for stationary discharges where a 

particular location and receiving water can be evaluated and applied with a discharge permit.

Commercial (non passenger) Vessels Wastewater Discharges

The typical composition of sewage and graywater discharges from non-passenger vessels has not 

been as extensively studied as cruise ship discharges. Most commercial, non-passenger vessels 

are equipped with Type I or Type II MSDs, so the composition of sewage discharges in terms of 

constituents and concentrations are likely to be similar to the cruise ship discharges evaluated by 

the EPA (2008a), except for cruise ships equipped with AWTS. The estimated total amount of 

sewage discharged in the sanctuary by non-passenger carrying, commercial vessels (including 

commercial fishing vessels, commercial vessels and tank vessels) is between 71,991 and 

392,676 gallons per year (Table 6). In sum, these vessels produced about 20% of the potential 

sewage and 23% of the potential graywater discharges into the OCNMS in 2009. 

Although the number of transits and vessel days for non-passenger vessels are many times 

greater than that of cruise ships, the total combined discharge volume from non-passenger 

vessels is much less because these vessels have substantially fewer passengers. 

Charter and Personal Recreational Vessel Wastewater Discharges

OCMNS is a popular recreational fishing area in the Pacific Northwest spanning Washington 

Department of Fish and Wildlife marine management units 2, 3, 4 and 4B. Private and charter 

vessels using the sanctuary originate primarily from the ports of Neah Bay, La Push, and 

Westport. In 2009, there were over 40,000 angler trips to the sanctuary. Of these trips about half 

were conducted on small private or charter vessels typically carrying 6 or fewer passengers. The 

remaining trips were conducted on larger charter vessels that carried an average of 10-13 

passengers. Reliable data regarding the type(s) of MSDs (if any) installed on these vessels is 

unavailable. The majority of these vessels are under 65 feet, so they could use any approved 

Type I, II, or III MSD, or could have no MSD of any type. 

The annual sewage discharge estimates for recreational and charter fishing vessels are between 

56,583 and 308,637 gallons based upon waste generation rates used for other vessel classes 
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(Table 6). Thus, these vessel classes potentially could contribute as much as 15.5% of sewage 

discharged to sanctuary waters. This likely overestimates true sewage discharges because these 

vessels are typically on day trips and may hold waste using a Type III MSD until it can be 

discharged at a shore-side pump-out facility. Waste generation rates may also be substantially 

lower due to the estimated short duration of fishing trips (six hours). Graywater discharge 

estimates were not calculated for recreational fishing vessels, as most would not have galleys or 

sinks, and therefore would not generate sizeable volumes of graywater. 

6.1.4 Climate/Meteorology

The maritime climate off the Olympic Coast is influenced by topography, location along the 

windward coast, prevailing westerly winds, and the position and intensity of high and low 

pressure centers over the North Pacific Ocean (Phillips and Donaldson 1972). The strong 

oceanic influence creates a climate of western Washington characterized by relatively mild 

winters and moderately dry, cool summers. In the late spring and summer, westerly to 

northwesterly winds associated with the North Pacific high pressure system produce a dry 

season. In late fall and winter, southwesterly and westerly winds associated with the Aleutian 

low pressure system provide ample moisture and cloud cover for the wet season beginning in 

October. Moist air transported across the ocean rises and cools on the windward terrestrial 

slopes, giving rise to relatively high rainfalls in western Washington. Annual rainfall amounts 

greater than 100 inches (254 cm) per year on the western portions of the Olympic Peninsula 

contribute to seasonally high inputs of river waters to the marine system. 

Large-scale oceanographic and atmospheric events across the Pacific basin also influence of 

Olympic Coast waters. For example, the El Niño-Southern Oscillation is primarily driven by sea 

surface temperatures along the equatorial Pacific Ocean and is a major source of inter-annual 

climate and ecosystem productivity variability in the Pacific Northwest, with events lasting 6 to 

18 months. Likewise, the Pacific Decadal Oscillation, a long-term cycle in ocean temperature 

with warm or cool phases that can each last 20 to 30 years, influences the climate in the Pacific 

Northwest. Climatic cycles such as these are natural events and often are associated with strong 

fluctuations in weather patterns and biological resources.

6.1.5 Climate Change

Over the next century, climate change is projected to profoundly impact coastal and marine 

ecosystems on a global scale, with anticipated effects on sea level, temperature, storm intensity 

and current patterns. At a regional scale, we can anticipate significant shifts in the species 

composition of ecological communities, seasonal flows in freshwater systems, rates of primary 

productivity, sea level rise, coastal flooding and erosion, and wind-driven circulation patterns 

(Scavia et al. 2002). Rising seawater temperatures may give rise to increased algal blooms, 

major shifts in species distributions, local species extirpations, and increases in pathogenic 

diseases (Epstein et al. 1993, Harvell et al. 1999). A better understanding of ocean responses to 

global scale climatic changes is needed in order to improve interpretation of observable 

ecosystem fluctuations, such as temperature changes, hypoxic events and ocean acidification that 

may or may not be directly coupled to climate change.
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6.2 BIOLOGICAL SETTING

Habitats are where organisms make their lives, where they survive, find food, water, shelter, and 

space. The collected habitats of an area create the place for the living ecosystem. Healthy 

marine habitats are the foundation of healthy communities of marine life. 

OCNMS is comprised of a broad diversity of habitats, some we can see from land, others hidden 

beneath the water, including rocky shores, sandy beaches, nearshore kelp forests, sea stacks and 

islands, open ocean or pelagic waters, as well as the continental shelf seafloor and submarine 

canyons. In addition to aquatic habitats in the sanctuary, islands and pinnacles, or sea stacks, 

along the coast provide nesting and resting sites for California and Steller sea lions, harbor and 

elephant seals, and thousands of seabirds. 

6.2.1 Intertidal Habitats

Most accessible to people is the intertidal zone, a habitat alternating between the dry and wet 

worlds where rock benches, tide pools and surge channels are formed amid boulders and rocky 

outcrops. These substrates provide both temporary and permanent homes for an abundance of 

“seaweeds” (e.g., macroalgae and seagrasses), invertebrates such as sea stars, hermit crabs, 

nudibranchs, snails, and sea anemones, and intertidal fish. Between rocky headlands are 

numerous sand-covered beaches and mixed rock/cobble benches hosting an array of intertidal 

invertebrates and fishes – food for both shorebirds and humans. Surf smelt spawn at high tide on 

sand-gravel beaches where surf action bathes and aerates the eggs.

Natural conditions in intertidal habitats of the Pacific Northwest challenge their inhabitants with 

extreme fluctuations in temperature, salinity and oxygen, along with powerful physical forces 

such as wave action and sand scouring. Yet, rocky shores of the Olympic Coast have among the 

highest biodiversity of marine invertebrates and macroalgae of all eastern Pacific coastal sites 

from Central America to Alaska (Suchanek 1979; Dethier 1992; PISCO 2002; Blanchette et al. 

in press). Macroalgae or seaweeds are highly diverse in the region, with an estimated 

120 species thought to occur within the sanctuary rocky intertidal zone (Dethier 1988).

With limited exceptions, nearshore and intertidal habitats in the sanctuary are remarkably 

undisturbed by human use and development (e.g., armoring, wetlands alteration, dredging, and 

land-based construction) that have modified shorelines in more urbanized areas. The remote 

location, low levels of human habitation, protections provided by the wilderness designation of 

Olympic National Park‟s coast, and restricted access to tribal reservations have allowed these 

coastal habitats to persist largely intact. At the few locations where shoreline armoring has been 

employed or where human visitation has focused on intertidal areas for food collection and 

recreation, impacts do not appear to be dramatic or widespread (Erickson and Wullschleger 

1998; Erickson 2005).

Monitoring conducted by Olympic National Park since 1989 indicates these habitats are healthy 

and do not appear to be changing substantially in response to human influences. Large-scale 

disturbances related primarily to extreme winter weather cause periodic damage to mussel beds 

(Paine and Levin 1981) and other intertidal species. Coastal ecologists recently have designed

studies to better detect changes resulting from effects of global climate change, such as sea level 

rise, increasing acidity and temperatures, and changes in storm frequency and magnitude. Local 
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trends in these parameters are uncertain, however, and no definitive results have yet been 

published. 

Relatively few nonindigenous or exotic species have been reported in the sanctuary, and, of 

those, only a few are invasive and therefore threatening to community structure and function 

(ONMS 2008). OCNMS-led rapid assessment intertidal surveys in 2001 and 2002 and a larvae 

settlement study (deRivera et al. 2005) identified a few nonindigenous species. One invasive 

species of concern, the green crab, has been found at sites both north and south of the sanctuary, 

but no green crab have be found through routine monitoring near the sanctuary. A program to 

prevent introduction and spread of invasive species is managed by Washington Department of 

Fish and Wildlife. 

Degradation of intertidal habitats, in the form of marine debris, is visible to even the casual 

visitor to the shore. The majority of this debris is plastic ranging from large floats to beverage 

bottles to tiny fragments the size of sand particles. Much of the debris originates from 

commercial fisheries, both international and domestic. 

6.2.2 Nearshore Habitats

In nearshore areas, canopy kelp beds form a productive, physically complex and protected 

habitat with a rich biological community association of fish, invertebrates and sea otters. Annual 

monitoring and quantification of the floating kelp canopy has been conducted since 1989 by the 

Washington Department of Natural Resources and in collaboration with OCNMS since 1995. 

Although the canopy changes every year, these kelp beds are generally considered stable, and the 

area covered by floating kelp has been increasing along the outer coast and western portion of 

the Strait of Juan de Fuca (Figure 5). This increase may be due in part to a growing population 

of sea otters and subsequent decline in grazing sea urchins or may be influenced by changes in 

oceanographic conditions. In contrast, extensive logging of the Olympic Peninsula, an area of

very high rainfall, has markedly increased sediment loads in rivers in the past. Long-term 

residents along the coast have noted a reduction in kelp beds near river mouths, which may have 

been associated with siltation of nearshore habitat and reduced light penetration (Chris 

Morganroth III, personal communication in Norse 1994). Recently documented, widespread 

hypoxic, or low oxygen conditions in nearshore areas off Oregon and Washington coasts have 

stressed and killed marine life. Such hypoxic conditions appear to be increasing in severity and 

frequency and may result from anomalous weather and oceanographic patterns. 

Nearshore habitats off sand beaches occurring all along the outer Olympic Coast and dominate 

the southern shores of the sanctuary tend to be less diverse, lacking macroalgae and physically

complex substrate. These are high energy environments where the inshore shelf is relatively 

shallow. Nutrients delivered by upwelling currents support phytoplankton biomass that is grazed 

and recycled by zooplankton. Wind and wave action support transport and retention of 

productive waters near shore, which sustains sand beach infaunal communities of amphipods, 

worms, and razor clams. 

Relatively few exotic or nonindigenous species have been reported in the sanctuary and, of those, 

only a few are invasive and therefore threatening to community structure and function in the 

nearshore. Observations by coastal ecologists from Olympic National Park and OCNMS of 

increased amounts of the invasive brown algae Sargassum muticum, the documented range 
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expansion of invasive ascidians (tunicates or sea squirts) (deRivera et al. 2005), and the 

encroachment of the invasive green crab to areas both south and north of the sanctuary all 

suggest negative impacts from nonindigenous species may increase in the future.

Figure 5 Kelp distribution

6.2.3 Pelagic (Water Column) Habitats

The pelagic habitat, or water column of the open ocean, is the most extensive habitat of the 

sanctuary. Many fish, seabird, and marine mammal species are pelagic and have relatively little 

association with seafloor or nearshore habitats. Phytoplankton at the base of the food web is 

most abundant in the euphotic, or sunlit, layer near the surface of the water column. This 

primary productivity supports a food chain based on grazing zooplankton, fish, and marine 

bacteria. Ocean productivity can be nutrient limited and is influenced by large-scale 

oceanographic currents and cycles. Seabirds can serve as indicators of productivity - poor 

survival of one year‟s young can indicate nutrient poor and low productivity cycles in the coastal 

marine system. Naturally occurring harmful algal blooms of plankton put humans and some 

marine wildlife at risk of biotoxin poisoning, either from plankton or from shellfish 

consumption. 

In some marine areas of the world, pelagic habitats have been degraded by chemical 

contaminants and wildlife conflicts with vessel traffic and noise pollution. Whereas variability 

in contaminant concentrations complicates characterization of water column pollutants, 

contaminants in animal and plant tissues can provide an integrated measure of bioavailability of 

compounds present at low or variable levels in the marine system. In the sanctuary, chemical 

concentrations were recently measured in a variety of invertebrates and sea otters for a study of 
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sea otter health (Brancato et al. 2009), the West Coast Environmental Monitoring and 

Assessment Program, and for NOAA‟s Status and Trends, Mussel Watch Program. Contaminant 

concentrations were found to be low in all organisms, with very few exceptions (ONMS 2008).

The potential for contamination of pelagic habitats by petroleum products is a concern reinforced 

by experience and justified by the volume of large vessel traffic at the western end of the Strait 

of Juan de Fuca. Four of the five largest oil spills in Washington state history have occurred in 

or moved into the area now designated as the sanctuary. In the decade before sanctuary 

designation, two major oil spills released more than 325,000 gallons of petroleum products 

impacting marine ecosystems and human communities on the outer Washington coast. 

Noise pollution, or the cumulative acoustic signature of human activities, is an aspect of the 

pelagic habitat of OCNMS not currently well characterized or evaluated for potential impacts on 

wildlife in the sanctuary. 

6.2.4 Seafloor Habitats

The ocean floor of the sanctuary covers over 3,300 square miles and is comprised of a variety of 

physically and biologically complex habitats. These habitats are shaped by the geology and 

topography of the seafloor and enhanced by living organisms like corals and sponges. Prior to 

development of remote sensing techniques, water depth measurements and bottom samples

provided spot data that was extrapolated to create crude seafloor maps. Modern exploration and 

detailed habitat mapping involves carefully planned and costly surveys from large vessels using 

sophisticated technology. Thus far, OCNMS has completed high resolution habitat mapping for 

about 25 percent of its seafloor, while information on remaining areas lacks resolution and 

specificity for development of accurate seafloor habitat maps (Figure 6). As a result, 

generalizations about the sanctuary‟s seafloor habitats and their biological communities are 

difficult to make.

The northern portion of the sanctuary is dominated by the Juan de Fuca Canyon and trough (the 

shallower extensions of the canyon closer to the Strait of Juan de Fuca), which are complex, 

glacially carved features containing a mixture of soft sediments, with significant cobble and 

boulder patches and scattered large glacial erratics (boulders) deposited during ice retreat. Highrelief, submerged topographic features serve as fish aggregation areas. Low-resolution surveys 

have revealed a generally wide and featureless continental shelf in the southern portion of the 

sanctuary dominated by soft substrates (sand and mud bottoms, to pebble and cobble) with 

scattered areas of rock outcrop and spires. The head of the Quinault Canyon also lies within the 

sanctuary boundary. 

Detailed information on historic and current conditions in the sanctuary‟s seafloor habitats is 

limited because technological challenges and expense have limited the areas that have been 

directly viewed. Thus, to a large extent the current condition of seafloor habitats must be 

inferred. The most widespread anthropogenic impact to seafloor habitats is likely to have 

resulted from the bottom trawl fishery using gear known to reduce complexity, alter the physical 

structure of seafloor habitats, and damage biogenic habitat, or habitat formed by living 

organisms, such as corals and sponges (NRC 2002; Auster et al. 1996, Auster and Langton 1999, 

Norse and Watling 1999, Thrush and Dayton 2002). Bottom trawling and long-line fishing has 

occurred widely throughout OCNMS for several decades, likely over all but the roughest of 
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seafloor habitats. Where biologically-structured habitats existed on the sanctuary seafloor, it is 

likely they have been altered by fishing practices, except perhaps in the roughest of terrain 

fishermen avoided. Recovery of biologically-structured habitats is expected to occur very 

slowly, even in the absence of future pressures, due to low growth and reproductive cycles of the 

habitat-forming organisms such as corals. 

Figure 6 Habitat map

In recent years, fishery management measures restricting footrope gear size and limit areas open 

to bottom trawlers, and in some places long-line and pot gear, have mitigated widespread 

seafloor impacts of bottom trawling and focused trawl effort more toward soft seafloor substrates 

where gear impacts on the physical habitat are less of a concern. 
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Analysis of seafloor habitat data used for groundfish Essential Fish Habitat (EFH) designation 

indicates that approximately six percent of the sanctuary is hard substrate with potential to host 

biologically structured habitat. Of this, 29 percent lies within the Olympic 2 EFH conservation 

area (Figure 7). Recent surveys by OCNMS researchers have documented corals and other 

biologically-structured habitat in other areas (Brancato et al. 2007), which indicates this analysis 

may underestimate the historic or current distribution of biologically-structured habitat. 

Figure 7 Potential historic distribution of biologically structured habitat associated with hard substrate 

overlaid on Olympic 2 EFH Conservation Area (data from Curt Whitmire, NOAA)

Submarine cable installations in OCNMS have been monitored and shown to cause acute and 

localized seafloor impacts, short-term habitat disturbance in soft sediments and more persistent 

physical disturbance in hard substrates (Brancato and Bowlby 2002). Cable trenching, however, 

impacts a very small portion of the sanctuary seafloor.
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Sediment contaminant levels (i.e., heavy metals and organic pollutants) in OCNMS are generally 

low and do not appear to be increasing (ONMS 2008). Marine debris does compromise seafloor 

habitat quality, but its impacts in OCNMS are not well-documented. Rough waters and complex 

seabed features increase the potential for fishing gear entanglement and loss. Studies from 

Puget Sound and beyond reveal that abandoned fishing gear can remain for decades, potentially 

entangling and killing species encountering the gear (NRC Inc. 2008). Assessment of derelict 

fishing gear on the seafloor has been limited to coastal areas around Cape Flattery and sites 

viewed for characterization of seafloor habitat and seafloor community studies. These later 

studies have documented lost fishing gear, most commonly long-line gear entangled on seafloor 

features and corals (Brancato et al. 2007). 

6.2.5 Benthic Invertebrates 

The majority of the sanctuary‟s seafloor where bottom dwelling, or benthic invertebrates live 

is composed of sand and mud. This submerged habitat is home to a variety of invertebrates 

similar to those found in intertidal areas – brittle stars, sea urchins, worms, snails, and shrimp. 

Dungeness crab and razor clams have long sustained commercial and recreational harvest off the 

Olympic Coast. 

Hard-bottom substrates harbor rich invertebrate assemblages, including deepwater coral and 

sponges (Brancato et al. 2007). These living organisms with branching, upright structure are, in 

turn, habitat where other invertebrates and fish find hiding places, attachment sites, food 

sources, and breeding and nursery grounds in relatively inhospitable and otherwise featureless 

environment (Whitmire and Clarke 2007). The distribution of such deepwater communities, as 

well as their species richness and basic biology, are not well documented but are currently under 

scientific investigation.

Human activities impacting seafloor habitats (described in section 6.2.4) can also harm benthic 

invertebrates. Submarine cable installation and buoy anchors can physically disturb and displace 

benthic invertebrates, but the cumulative area of impact is relatively small given small size of 

most anchors and the narrow path of disturbance and relatively few cables installed in the area 

(Brancato and Bowlby 2002). The most widespread human impact to benthic invertebrates 

likely results from bottom contact fishing gear, especially bottom trawl fisheries with footropes 

and roller gear repeatedly traversing relatively wide swaths of the seafloor. 

6.2.6 Fishes

Among the many species of fish inhabiting OCNMS are commercially important ones including

at least 30 species of rockfish, 15 or more species of flatfish, Pacific halibut, Pacific whiting (or 

hake), sablefish, and salmon. Five species of Pacific salmon (chinook, sockeye, pink, chum and 

coho) occur along the outer coast of Washington and breed in the Olympic Peninsula‟s rivers and 

streams. Three similar salmonid species found in freshwater systems (sea-run cutthroat trout, bull 

trout, and steelhead) spend portions of their lives in nearshore marine waters. Nearshore habitats 

of the sanctuary presumably are important for salmon spawning in adjacent streams and rivers, 

but juvenile salmon use of nearshore habitats off the Olympic Coast is not well understood. The 

sanctuary also is part of the migration corridor of both juvenile and adult salmonids from 

California, Oregon, British Columbia, and Washington rivers beyond the Olympic Peninsula. 
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Migratory species, such as sharks, albacore, sardines, mackerel, and anchovies, are important 

resources for tribal and non-tribal fishers that are found in the sanctuary seasonally.

Federal and Washington state listings of candidate, sensitive, threatened, or endangered species 

are definitive indicators that some fish populations are not healthy. Olympic Coast populations 

of Ozette sockeye and bull trout have been on the federal list of threatened species in 1999. 

Thirteen species of rockfish are identified as state species of concern, and three of these are also 

federal species of concern. In recent decades, West Coast groundfish stocks and fisheries were

in crisis, with steep declines in commercial ex-vessel value, overcapitalization, and several 

groundfish stocks depleted by a combination of fishing and natural factors (NMFS 2002). Four 

species of rockfish found in the sanctuary have been classified as overfished by the NMFS

Service (NMFS 2006a). And there have been increasing concerns about our limited ability to 

forecast groundfish production from single species investigations is missing important natural 

and fishery-induced changes in the ecosystem and will not be able to forecast truly sustainable 

harvest policies (NMFS 2002). For example, age structure, an important measure of population 

integrity, has been affected by fisheries. Some rockfish populations have been shown to have 

reduced numbers of larger, older fish, a factor that could affect their recovery rate (PFMC 

2008a). Older rockfish produce more eggs and more robust juveniles (Berkeley et al. 2004). 

However, in most cases, the status of the larger, older fish within the population is unknown 

because it has not been determined whether the older fish are simply missing because they have 

been removed from the population, or are not fully represented in fishery or stock assessment 

surveys.

However, professional fisheries managers generally are optimistic sustainable fisheries off the 

outer coast of Washington are possible under new management regimes following these 

historical stock declines. Recent fishery management measures implemented to reduce fishing 

effort, monitor and minimize bycatch, and reduce impacts to habitat appear to have assisted 

initial recovery of some overfished groundfish stocks and provide evidence for an improving 

trend (ONMS 2008).

6.2.7 Seabirds

Seabirds are the most conspicuous members of the offshore fauna of the Olympic Coast. Sea 

stacks and islands provide critical nesting habitat for 19 species of marine birds and marineassociated raptors and shorebirds, including seven alcid species (including murres, puffins, and 

murrelets), three cormorant species, four gull and tern species, two storm-petrel species, two 

raptors and one shorebird, the Black Oystercatcher. Productive offshore waters also attract large 

feeding aggregations of marine birds that breed in other regions of the world but travel great 

distances to “winter” in sanctuary waters. The Sooty Shearwater, for example, breeds off New 

Zealand and Chile in the austral summer and congregates along the Pacific coast in its nonbreeding season. Black-footed and Laysan Albatross travel far from their breeding grounds in 

Hawaii and Japan to forage in the eastern Pacific. Nearer to shore, sand and gravel beaches are

foraging areas for shorebirds, crows, gulls and a host of other birds. The coastline also forms an 

important migratory pathway for millions of birds that pass through each year, guiding 

waterfowl, cranes, shorebirds and raptors toward northern breeding areas during the spring and 

southward as winter approaches.
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Seabirds are relatively numerous, conspicuous, and forage across multiple habitat types and 

trophic levels. For these reasons, they are often considered indicators of ocean conditions, and 

the status of their populations provides insight into ecosystem health (Parrish and Zador 2003, 

Piatt et al. 2007). Many feed on forage fish, a critical link in the food chain, which are difficult 

to quantify by direct observation or sampling. Populations of five species of marine birds 

breeding in the sanctuary are declining in the area, which has led to their inclusion on federal or 

state species of concern lists: Common Murre, Marbled Murrelet, Tufted Puffin, Cassin‟s Auklet, 

and Brandt‟s Cormorant. Trends and common concerns for these seabirds are long-term declines 

in their population sizes (Wahl and Tweit 2000, Wahl et al. 2005, Raphael 2006); vulnerability to 

human disturbances such as oil spills, habitat disruption and fisheries bycatch (Piatt et al. 2002, 

Raphael 2006); and susceptibility to natural disturbances such as ENSO events (Graybill and 

Hodder 1985, Wilson 1991, Piatt et al. 2002, Wahl et al. 2005). Although some population 

levels appear to be stabilizing at values lower than historical levels, a longer time series is 

needed to determine a trend (Lance and Pearson 2008).

A closer examination of the Common Murre population provides insight into some factors 

affecting the status of all seabirds on the Washington coast. The murre population declined 

dramatically in 1982 and 1983, coinciding with a severe El Niño-Southern Oscillation (ENSO), 

and has not recovered to pre-1983 levels since that time (Warheit and Thompson 2004). Aside 

from declines associated with ENSO events, it has been suggested the population has not 

recovered due to a combination of oil spills, disturbance at breeding colonies (e.g., historic Naval 

bombing practices), and gillnet mortality (Warheit and Thompson 2004). During the Nestucca

spill in 1988 and Tenyo Maru spill in 1991, over 70% of bird carcasses recovered were Common 

Murres, mortalities that represented a sizable proportion of the total Washington state Common 

Murre population (The Tenyo Maru Oil Spill Natural Resource Trustees 2000). Although the 

Common Murre population showed signs of recovery through the 1990s, the number of birds has 

diminished greatly relative to pre-spill numbers, and modest declines have been found in recent 

years (Manuwal et al. 2001). At the breeding colony on Tatoosh Island, Common Murre 

populations have also been affected by an influx of avian predators, including Bald Eagles, 

Peregrine Falcons and nest-depredating Glaucous-winged Gulls (Parrish et al. 2001). These

multiple stressors affecting the sluggish recovery of Common Murres may be indicative of the 

challenges facing the long-term recovery of other seabirds.

Age structure and mortality rates are also in question in some bird populations on the coast. 

Common Murres on Tatoosh Island have experienced documented breeding failures during 

recent years, partially attributed to oil spills and observed heavy predation by raptors and gulls, 

but also possibly due to low food supply during critical breeding periods (Parrish et al. 2001, 

Warheit and Thompson 2003). Because they are long-lived, an occasional year of poor 

productivity may not impact the population significantly, but multiple years or successive years 

of breeding failure would likely have future impacts on the population. Recent demographic 

studies of Marbled Murrelets in the region have indicated they have had low nesting success in 

recent years (Raphael and Bloxton 2008), which may inhibit their recovery or at least slow the 

rate of recovery.

6.2.8 Marine Mammals

Twenty-nine species of marine mammals have been sighted in Olympic Coast National Marine 

Sanctuary. Whales, because of their size, abundance and visibility, are commonly seen in the 
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sanctuary. Sea otters, harbor and elephant seals, and Steller and California sea lions aggregate 

along the shore and haul out on land at many locations along the coast throughout the year. The 

humpback whale and the killer whale (also called orca) forage offshore, and some 20,000 gray 

whales travel through the sanctuary on their annual migrations between breeding and calving 

grounds off the Baja Peninsula and summer feeding grounds in the northern Pacific. Eleven 

marine mammal species are on either federal or state species of concern lists across their range 

(Washington Department of Fish and Wildlife 2008).

The sea otter is often considered a keystone species because of the strong top-down influence 

they have on the nearshore kelp ecosystem. Sea otters are of high scientific interest because they

were extirpated from Washington state by commercial pelt hunters by 1911, then were 

reintroduced in 1969 and 1970 (Lance et al. 2004). This population has been counted annually 

since 1989 and has shown increases the past few years, with a peak of 1,121 animals in 2008 

(Jameson and Jeffries 2008). The rate of population growth, however, has been slower than 

expected (Laidre et al. 2002; Lance et al. 2004). The sea otter remains a federal species of 

concern and an endangered species within Washington state, and the population remains 

vulnerable because of its small size, limited genetic diversity, existing exposure to pathogens, 

and extreme risks to oil spills. 

Most wildlife populations in the sanctuary are relatively healthy and unburdened by 

contaminants, pathogens or related maladies. There are, however, notable exceptions. Although 

no negative health effects have been documented, the sea otter population has been shown to 

carry several potentially lethal pathogens - 80 percent of the otters tested positive for the 

distemper viral complex Morbillivirus and 60 percent tested positive for the protozoan 

Toxoplasma gondii (Brancato et al. 2009). Fat-soluble contaminants are generally considered to 

bioaccumulate or increase in concentration when moving up the food web (Cockcroft et al. 

1989). Overall, tissue concentrations of assayed contaminants were relatively low in 

Washington sea otters (Brancato et al. 2009). However, other top predators in the region, such as 

killer whales, have been shown to carry high contaminant loads (e.g., PCBs and PBDEs) in their 

blubber (Ross et al. 2000, Ross 2006), though the population effects of such high contaminant 

loads are unknown.
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6.3 CULTURAL AND HISTORICAL SETTING

Olympic Coast National Marine Sanctuary has a rich maritime heritage where lives, languages, 

communities and cultures are continuously shaped by the sea. The native Makah, Quileute, Hoh 

and Quinault peoples traditionally lived at the water's edge, thriving on the riches of the ocean 

plants, fish, shellfish, seabirds and marine mammals. The waters off the Washington coast linked 

native peoples along the coast as they traveled by canoe. These waters were highways that were 

traversed by canoes and, more recently, ships supporting communities and industries along the 

shores of the Strait of Juan de Fuca and Puget Sound and beyond. Historically, local maritime 

activity ranged from fur hunting, whaling and fishing, to coastal trade with smaller coastal 

communities. The rugged Olympic Coast could be treacherous, especially during winter storms 

when high winds and strong currents pushed ships dangerously close to the rocky islands, reefs 

and shoreline. Fog, too, led to collisions with disastrous results. Over 180 ships were reported 

wrecked or lost at sea in or near sanctuary waters in the years between 1808 and 1972.

6.3.1 American Indian Cultural Resources

The modern shoreline of the Olympic Peninsula contains dozens of late prehistoric archaeological 

sites rich in materials documenting the character of the maritime environment and the use of this 

environment by the region‟s native peoples. Nearshore coastal forests adjacent to the sanctuary 

contain mid-Holocene shorelines and older prehistoric archaeological sites. These older sites are 

rich in materials documenting the character of maritime paleo-environments, the history of 

environmental change, and the record of use of these environments by the region‟s native peoples. 

The earliest dated archaeological site on the Washington Coast occurs adjacent to the sanctuary 

on the Makah Indian Reservation, establishing human presence for the last 6,000 years. The 

recent investigation of paleoshoreline sites on the Makah Reservation reveals high sea-stand 

village sites inland along the Sooes and Waatch river valleys, in some cases greater than 10 

meters above current sea level and kilometers from the current ocean shore (Wessen 2003). 

These sites indicate complex interactions with marine resources of the period and yield important 

clues to large-scale ocean and climate regimes, marine wildlife and fish populations, habitat 

distribution and cultural patterns of marine resource use. The Makah Cultural and Research 

Center in Neah Bay houses an extraordinary collection of artifacts from the Ozette 

archaeological site, a Makah village that was partially buried by a mudslide nearly 500 years ago 

and excavated in the 1970s. 

Other tangible records of prehistoric human occupation include petroglyphs both above the 

intertidal zone and within it, middens of shells and other discarded domestic materials, and canoe 

runs, or channels cleared of boulders to facilitate landing of dugout watercraft. Research and 

preservation of coastal native languages, traditional cultural properties, and traditional practices 

of song, dance and activities like whaling also enhances awareness in native and non-native 

peoples of the region‟s rich ocean-dependent heritage. The recent resurgence of the canoe 

culture in the annual “Tribal Journeys” celebration transfers knowledge and understanding of 

coastal culture to new generations.
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6.3.2 Historical and Archaeological Resources

Historical-era resources are generally affiliated with archaeological remains of the western 

cultures that appeared in the region by the mid-nineteenth century. A combination of fierce 

weather, isolated and rocky shores, and thriving ship commerce have made the Olympic Coast a 

graveyard for ships of many descriptions. 

6.3.2.1 Historical Contexts

Early European-led visits to the Pacific Northwest were explorations to map the coast, assess 

marketable natural resources, and stake claim to lands. Juan Perez, a Spaniard, sailed from 

Mexico on the first European exploration of the Pacific Northwest in1774, an expedition that 

extended as far north as the Alaskan panhandle. In 1778, James Cook explored the coast 

between Oregon and Alaska. By the 1790s, Spain attempted to use the region as a buffer against 

encroaching Russian and English fur hunters. In 1792, the Spanish established a short-lived 

palisaded settlement known as Nunez Gaona near the mouth of the Strait of Juan de Fuca in 

Neah Bay to support their main base on Vancouver Island. This Spanish settlement lasted less 

than a year.

As the British settled Canada's Pacific Northwest, Americans also continued their westward 

migrations into the United States northwestern territories of Washington and Oregon. A need for 

timber to support the population explosion resulting from California's 1849 Gold Rush led to the 

settlement and exploitation of the timber resources around Puget Sound and the Olympic 

Peninsula. An increase in shipping around Cape Flattery resulted in an increase in ship losses. 

The U.S. Lighthouse Board built lighthouses at both Destruction Island and Tatoosh Island to 

reduce the hazards to the increased shipping.

The encroachment of settlers had a profound impact on the native tribes‟ traditional way of life. 

The United States pressured the tribes to move to reservations in order to make way for 

American settlement. In 1855, the Treaty of Neah Bay set aside land at Cape Flattery as a 

reservation for the Makah tribe. Tatoosh Island was appropriated for the lighthouse and was not 

returned to the tribe until 1984. In 1855-1856, the ancestors of the Hoh Tribe, Quileute Tribe

and the Quinault Indian Nation signed the Treaty of Olympia with the U.S. Government. The 

Hoh and Quileute reservations were subsequently established by Executive Order. 

Throughout the 1850s and 1860s, settlers moved onto lands formerly used by American Indians. 

The remoteness and lack of access roads to areas near the coast prevented an influx of large 

numbers of settlers, but small western communities, such as Port Angeles and Port Townsend

began to appear near American Indian communities that persisted in Neah Bay, La Push, and 

Taholah. Grays Harbor, too, became a center of timber export. By the last quarter of the 

nineteenth century, small sailing vessels and steamers used for fishing, whaling and local 

commerce were commonly seen alongside native canoes. 

Since the mid-1990s, NOAA's Office of National Marine Sanctuaries has compiled and 

periodically updated a database of historic ship and military aircraft losses that includes known 

 

 The term "historical" refers to cultures with written language.
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archaeological resources in the vicinity of Olympic Coast National Marine Sanctuary. 

Approximately 207 historic ships have been documented as lost in what is now the sanctuary 

between the early-nineteenth and mid-twentieth centuries (Schwemmer 2008). As the rate of 

shipping increased with the growing regional economy and settlement, so too did the rate of 

shipwreck increase off the Olympic Peninsula. An assessment of the database indicates the 

majority of losses were weather-related, including founderings, collisions and groundings. Many 

ships simply vanished after sailing past Tatoosh lighthouse, their resting place never known. 

Ship types ranged from clippers and multi-sail rigged windjammers, to steam freighters, small 

gasoline powered fishing boats and barges. There are a number of ships that have entered local 

lore and are still remembered by local citizens of the peninsula. Examples include:

SS Skagway - On December 16, 1929, the Dollar line steam freighter, Skagway, caught fire and 

drifted into the rocks around Fuca Pillar at Cape Flattery. The rocks where she went down have 

since been referred to as Skagway Rocks.

W.J. Pirrie - The five-masted iron ship Pirrie had been reduced to a sailing barge after almost 

forty years of sailing when it hit the rocks during a storm on November 11, 1920. Sixteen crew 

(including the captain's wife and young child) drowned and were washed ashore around Cape 

Johnson. Because the ship had Chilean registry at the time of its sinking, she became known as 

the "Chilean Wreck" and is so commemorated by a monument at the site where most of the 

bodies were recovered.

SS Pacific - Perhaps one of the greatest shipwreck mysteries of the Olympic Coast involves the 

sidewheel steamer Pacific, lost in 1851. The ship was steaming for Panama out of Victoria and 

reportedly carrying miners from the British Columbia gold fields when she collided with another 

ship. Only two of almost three hundred passengers survived. Treasure salvors have sought the 

ship in the past in the belief the miners on board may have been carrying unreported gold in their 

baggage and on their persons. The ship has not yet been located.

Two locally well-known wrecks (among several others) occurred in the vicinity of La Push. One 

of the earliest recorded local wrecks was the Russian brig St. Nicholas on Rialto Beach in 1808. 

Several of the crew were captured by Native Americans and their ordeal was a well-told story. 

The earliest steam shipwreck in the sanctuary region was the Southerner in 1854. A wooden 

sidewheel steamer built in 1846, Southerner served as a passenger steamer when it sprang a leak 

and the captain was forced to run her ashore at First Beach at Quillayute (now La Push). The 

large island situated at the mouth of Quillayute River, originally called Alekistet Island by the 

Quileute tribe, was renamed James Island by the white settlers to honor Francis W. James who 

scaled it in order to watch over the remains of the ship and protect it from illegal salvage (Terrell

no date).

6.3.2.2 Archaeological Resources

In compliance with Section 110 of the National Historic Preservation Act, OCNMS undertook 

five surveys to document historical shipwrecks between 1995 and 2001. Utilizing acoustic and 

magnetic remote sensing and diver target identification, the research design identified areas of 

high probability for finding historically-reported shipwrecks near the southern shore of the Strait 
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of Juan de Fuca, the vicinity of Tatoosh Island, Cape Flattery to Portage Head, as well as select 

areas at Cape Alava, La Push/Quilleyute Needles and Destruction Island. 

Often searching in difficult and dangerous nearshore areas, the teams were able to locate remains 

associated with at least eight historic shipwrecks. A draft final report was compiled and a draft 

manuscript is presently on file at OCNMS. The report concludes the majority of the wreck 

remains in nearshore waters have been severely degraded due to heavy storm and wave impact. 

Several of the sites, which were found using sidescan sonar, could not be safely dived or

documented by marine archaeologists. 

Thus far, two historic shipwreck sites have been documented by the OCNMS. The remains of 

the World War II/Korean War troopship General M.C. Meigs at Portage Head was examined by 

diving archaeologists in 1997. Although scattered and broken in half, much material remaining 

should be documented further. Also, in 1997 a team investigated the nearshore remains of a 

nineteenth-century bark, the Austria at Cape Alava. Almost all wooden remains have been 

destroyed by the environment, but the team was able to locate the orientation of the wreck by the 

locations of significant objects such as the ship's anchor, anchor chains and hawseholes. The site 

subsequently has been used as an educational tool to teach students about the maritime heritage 

resources of the sanctuary.

Final recommendations in the report included further study of several sites, and focus of

OCNMS‟ future efforts towards locating historical shipwreck remains in deeper water. The lack 

of exposure to winter storms suggest a better probability of preservation of submerged 

archaeological remains (Terrell no date).

6.3.2.3 Maritime Cultural Landscape

The National Historic Preservation Act directs federal agencies like NOAA to inventory and 

manage heritage resources, and, if appropriate, to nominate those properties to the National 

Register of Historic Places. The act also recommends agencies interpret the cultural landscape 

of a region. A search of National Register listings indicate three properties adjacent to the 

OCNMS. They are:

 Ozette Indian Village Archaeological Site

 Tatoosh Island

 Wedding Rock Petroglyphs

In addition to archaeological remains exhibiting the tribes' relationship with the sea, the region's 

Indian cultural landscape may contain (among other things) such elements of culture as stories, 

dances, traditional knowledge and practices, traditional place names and language. Even the 

tribe's renewed interest in canoe construction and navigation and whaling represent the 

prehistoric and tribal maritime cultural landscape.

So it is with historic maritime cultural landscapes. Archaeological remains of shipwrecks are but 

one component. Historic structures on land, while technically outside of sanctuary boundaries, 

remain as important tangible fragments of the past and provide insight into past human 

interactions with the ocean. These include historic lighthouses at Tatoosh and Destruction 

islands, lifesaving station remnants at Waadah Island and La Push, wartime defense sites at Cape 
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AFFECTED ENVIRONMENT

Flattery and Anderson Point, and sites of coastal patrol cabins scattered along the Olympic 

Coast. Homesteads, resorts, graves, and memorials also reflect a human dimension to the coast 

now largely reclaimed by time, the forest, or the sea. The oral traditions, stories, fishing 

practices and local lore also are components of the historical maritime cultural landscape.
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6.4 HUMAN/SOCIOECONOMIC SETTING

The Olympic Peninsula has a rich history supporting diverse commercial, recreational, cultural, 

research and education activities. Western and American Indian populations alike, including the 

Hoh, Makah, Quileute, and Quinault peoples, utilize plant, fish, and shellfish resources, as well 

as the access and transportation routes within and adjacent to the sanctuary as an integral part of 

economic and socioeconomic activities. This section describes the character of the sanctuary and 

adjacent areas, including the population, overall economy, employment and housing. For the

purposes of this analysis, the discussion of the affected environment is focused on those areas 

immediately adjacent to the sanctuary. Additional discussion focuses on the commercial activity 

dependent on the sanctuary area.

6.4.1 Population, Housing, Income, and Employment

Table 8 shows information on population, housing, poverty and income in counties immediately 

adjacent to the sanctuary. Despite the recent economic recession, populations, housing and 

incomes in Clallam, Grays Harbor and Jefferson counties have increased over the last decade. 

However, the percentage of the population with an income below the poverty level in each 

county has also increased over same period.

Table 8 Population, housing and income for counties adjacent to OCNMS

Clallam County Grays Harbor County Jefferson County

2000 2009 2000 2009 2000 2009

Population 64,525 71,413 67,194 71,797 25,953 29,676 

Housing Units 30,683 33,972 32,489 34,692 14,144 16,291 

Area in Square Miles 1,739 1,739 1,917 1,917 1,814 1,814 

Total Population Density per sq. mi. 37.1 41.1 35.1 37.5 14.3 16.4 

Median Household Income $37,420 $47,537 $34,724 $41,787 $39,519 $50,463 

Poverty Status (% below poverty level) 12.1% 13.6% 15.0% 15.9% 10.7% 12.4%

Source: U.S. Census Bureau 2000; Washington State Office of Financial Management 2009.

Table 9 shows information from the 2000 census on population, housing, poverty and income in 

American Indian communities in the vicinity of the OCNMS. All Coastal Treaty Tribes have 

experienced, and in many cases still experience, high unemployment and poverty rates. Much of 

the tribal culture and economy is resource-based and focused on commercial fishing, timber, and 

tourism. 

Employment opportunities on American Indian reservations are much less diverse, given the 

smaller populations, and cultural and geographic isolation from major population centers. Much 

of the mainland adjacent to the sanctuary consists of sparsely populated areas under federal or 

tribal management, as well as sizeable tracts of privately-owned timberlands. The public areas 

outside tribal reservations are managed by the National Park Service, or administered by state or 

county governments. 
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Table 9 Population, housing and income for American Indian Tribes adjacent to OCNMS

Population, Housing and Income Makah Tribe Quileute Tribe Hoh Tribe Quinault Nation

Population 1,356 371 102 1,370 

Housing Units 534 128 33 406 

Area in Square Miles 47.0 1.6 0.7 316.3 

Total Population Density 28.9 236.6 137.1 4.3 

Median Household Income $24,091 $21,750 $21,875 $26,488 

Poverty Status (% below poverty level) 26.8% 34.5% 42.0% 31.5%

The Coastal Treaty Tribes are dependent economically, culturally and spiritually upon natural 

resources found on their reserved lands and within their usual and accustomed hunting, fishing 

and gathering areas. Much of the tribal economies are resource-based, focused on commercial 

fishing, timber and tourism. Commercial fishing is one of the mainstays of the tribal economies, 

with emphasis on Dungeness crab, groundfish, salmon and steelhead, blackcod (sablefish) and 

razor clams (see section 6.4.3). 

As with the rest of the Olympic Peninsula, while natural resources continue to support the area 

economy, tourism is growing in importance for the Coastal Treaty Tribes, particularly 

recreational fishing, nature viewing and active water sports (surfing and kayaking; section 6.4.8). 

The Quinault Indian Nation runs a successful casino in Ocean Shores. The Quileute Tribe runs a 

very popular resort and marina, and more recently with the overwhelming success of the 

Twilight books and movies has become a popular tourist destination. The Makah Tribe also runs 

an important regional marina and one of the most popular museums in Washington state, the 

Makah Cultural and Historical Center.

The following sections describe the importance the resources within the boundaries of the 

sanctuary play in the economic and socioeconomic lives of the coast‟s residents, residents of 

Puget Sound, as well as the wider community dependent on sanctuary access. The potential for 

effects on the human/socioeconomic setting derive mostly from these activities.

Employment opportunities on American Indian reservations are much less diverse, given the 

smaller populations, and cultural and geographic isolation from major population centers. Much 

of the mainland adjacent to the sanctuary consists of sparsely populated areas under federal or 

tribal management, as well as sizeable tracts of privately-owned timberlands. The public areas 

outside tribal reservations are managed by the National Park Service, or administered by state or 

county governments. 

The Coastal Treaty Tribes are dependent economically, culturally and spiritually upon natural 

resources found on their reserved lands and within their usual and accustomed hunting, fishing 

and gathering areas. Much of the tribal economies are resource-based, focused on commercial 

fishing, timber and tourism. Commercial fishing is one of the mainstays of the tribal economies, 

with emphasis on Dungeness crab, groundfish, salmon and steelhead, blackcod (sablefish) and 

razor clams (see section 6.4.3). 
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As with the rest of the Olympic Peninsula, while natural resources continue to support the area 

economy, tourism is growing in importance for the Coastal Treaty Tribes, particularly 

recreational fishing, nature viewing and active water sports (surfing and kayaking; section 6.4.8). 

The Quinault Indian Nation runs a successful casino in Ocean Shores. The Quileute Tribe runs a 

very popular resort and marina, and more recently with the overwhelming success of the 

Twilight books and movies has become a popular tourist destination. The Makah Tribe also runs 

an important regional marina and one of the most popular museums in Washington state, the 

Makah Cultural and Historical Center.

The following sections describe the importance the resources within the boundaries of the 

sanctuary play in the economic and socioeconomic lives of the coast‟s residents, residents of 

Puget Sound, as well as the wider community dependent on sanctuary access. The potential for 

effects on the human/socioeconomic setting derive mostly from these activities.

Table 10 shows information on 2008 employment in counties adjacent to OCNMS. The 

government service, wholesale/retail trade, manufacturing and healthcare sectors dominate 

employment in the three counties, providing 68 percent, 71 percent and 71 percent in Jefferson, 

Clallam, and Grays Harbor counties, respectively. By contrast, only 1 percent, 2.8 percent and 

3.6 percent of employment relies on the agriculture, forestry, fishing, and hunting sector in 

Jefferson, Clallam and Grays Harbor, respectively. Tourism, driven by the natural beauty and 

resources of the Olympic Peninsula, is a growing economic driver, and its impact is spread 

across several of the employment sectors shown, including fishing and hunting, retail trade, arts, 

entertainment and recreation and accommodation and food service.

Employment opportunities on American Indian reservations are much less diverse, given the 

smaller populations, and cultural and geographic isolation from major population centers. Much 

of the mainland adjacent to the sanctuary consists of sparsely populated areas under federal or 

tribal management, as well as sizeable tracts of privately-owned timberlands. The public areas 

outside tribal reservations are managed by the National Park Service, or administered by state or 

county governments. 

The Coastal Treaty Tribes are dependent economically, culturally and spiritually upon natural 

resources found on their reserved lands and within their usual and accustomed hunting, fishing and 

gathering areas. Much of the tribal economies are resource-based, focused on commercial fishing, 

timber and tourism. Commercial fishing is one of the mainstays of the tribal economies, with 

emphasis on Dungeness crab, groundfish, salmon and steelhead, blackcod (sablefish) and razor 

clams (see section 6.4.3). 

As with the rest of the Olympic Peninsula, while natural resources continue to support the area 

economy, tourism is growing in importance for the Coastal Treaty Tribes, particularly 

recreational fishing, nature viewing and active water sports (surfing and kayaking; section 6.4.8). 

The Quinault Indian Nation runs a successful casino in Ocean Shores. The Quileute Tribe runs a 

very popular resort and marina, and more recently with the overwhelming success of the 

Twilight books and movies has become a popular tourist destination. The Makah Tribe also runs 

an important regional marina and one of the most popular museums in Washington state, the 

Makah Cultural and Historical Center.
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Table 10 Employment in counties adjacent to OCNMS (2008)

JEFFERSON COUNTY CLALLAM COUNTY

GRAYS HARBOR 

COUNTY

Avg. # of 

Employees Wages Paid

Avg. # of 

Employees Wages Paid

Avg. # of 

Employees Wages Paid

(Percent of 

Workforce)

(Percent of 

Total)

(Percent of 

Workforce)l

(Percent of 

Total)

(Percent of 

Workforce)

(Percent of 

Total)

Agriculture, Forestry, 

Fishing & Hunting 1.2% 1.0% 2.4% 2.8% 3.6% 3.6%

Mining 0.6% 0.8% 0.0% 0.1% 0.3% 0.3%

Utilities 0.7% 1.6% 0.1% 0.1% 0.0% 0.0%

Construction 6.9% 7.8% 5.7% 6.2% 5.8% 7.2%

Manufacturing 8.3% 11.9% 6.1% 8.2% 16.4% 20.6%

Wholesale/Retail Trade 12.6% 10.3% 16.7% 13.9% 14.0% 11.9%

Transportation & 

Warehousing 0.7% 0.6% 2.0% 2.1% 2.4% 2.4%

Information 1.6% 1.9% 1.3% 1.4% 0.9% 1.0%

Finance, Insurance, & 

Real Estate 3.9% 3.5% 3.4% 3.1% 3.5% 3.4%

Professional & Tech. 

Services 2.6% 2.7% 2.4% 2.6% 1.5% 1.8%

Management of 

Companies & Enterprises 0.0% 0.7% 1.4% 0.2% 0.3%

Administrative & Waste 

Services 1.7% 1.2% 1.9% 1.3% 2.0% 1.7%

Educational Services 1.7% 1.1% 0.3% 0.1% 0.0% 0.0%

Health Care & Social 

Assistance 15.7% 14.3% 11.2% 9.2% 9.0% 9.5%

Arts, Entertainment,& 

Recreation 1.3% 0.8% 1.0% 0.5% 0.9% 0.4%

Accommodation & Food 

Services 12.2% 5.2% 9.6% 4.0% 8.7% 3.5%

Other Services, except 

Public Administration 5.1% 3.7% 4.9% 3.0% 5.5% 2.7%

Government 23.3% 31.5% 30.3% 40.0% 25.2% 29.5%

Not Elsewhere Classified 0.1% 0.1%

The following sections describe the importance the resources within the boundaries of the 

sanctuary play in the economic and socioeconomic lives of the coast‟s residents, residents of 

Puget Sound, as well as the wider community dependent on sanctuary access. The potential for 

effects on the human/socioeconomic setting derive mostly from these activities.
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6.4.2 Maritime Transportation

Maritime transportation within the sanctuary includes both vessels in transit, simply passing 

through the sanctuary under way to another destination, and vessels within the boundaries of the 

sanctuary for a particular purpose. An understanding of vessel activity is necessary for sanctuary 

management for a number of reasons, both from a perspective of potential impacts from vessel 

activities and also from a more general perspective of characterizing human activities within the 

sanctuary. In very broad terms most vessels found within the sanctuary can be described as large 

commercial vessels, commercial fishing vessels and recreational vessels.

The sanctuary lies at the entrance to the Strait of Juan de Fuca, a major international waterway 

linking the important North American ports of Seattle, Tacoma, and Vancouver, Canada, with 

trading partners all around the Pacific Rim. Every year, approximately 10,000 large commercial 

vessel transits occur at the western end of the Strait of Juan de Fuca. The uses of sanctuary 

waters for maritime transportation, along with commercial fishing, are the most significant 

commercial uses of the sanctuary. The total number of transits of vessels participating in the 

Cooperative Vessel Traffic Service (CVTS) off the Olympic Coast in 2009 are summarized in 

Table 11, along with the duration of their transit. These data were derived from observations by 

the Canadian Coast Guard Marine Communications and Traffic Services (MCTS) Tofino Radar 

facility. Public vessels are those engaged in work for the government or public institutions (e.g., 

Coast Guard, research, spill response).

Cruise ship operations generally utilize the sanctuary for purposes of transit, simply passing 

through the sanctuary inbound to the Ports of Seattle and Vancouver, Canada or outbound to 

Alaska and other cruise destinations in the Pacific or other U.S. or foreign ports. However, the 

economic impact of the cruise ship industry in the region is substantial, and includes spending 

and jobs related to ship supplies, repairs and maintenance, fuel, stevedoring, port costs, pilotage, 

hotel accommodations for passengers and crew, local tours and shopping, restaurants, buses, 

taxis and air transportation. The Port of Seattle estimates the cruise industry in 2008 produced 

1,955 direct jobs, 1,125 induced jobs, and 701 indirect jobs in the Puget Sound area alone from 

ships transiting the sanctuary. The Port of Seattle also estimates the cruise industry generated 

$312.5 million in business revenue and $16.1 million of state and local taxes in the Puget Sound 

(POS 2009). The North West and Canada Cruise Association estimates in British Columbia 

alone, the estimated spending by the ships, passengers and crew is in excess of $500 million 

(Canadian) per year. The Association estimates similar numbers for Alaska, where recent 

studies cite more than $700 million (US) in annual economic benefits directly tied to the 

industry.

Vessel traffic in northern portion of the sanctuary is managed through a 1979 formal agreement 

between the Canadian and United States Coast Guards. This agreement created the Cooperative 

Vessel Traffic Service (CVTS). The purpose of the CVTS is to provide for the safe and efficient 

movement of vessel traffic while preventing collisions and groundings, and therefore minimizing 

the risk of environmental damage that would follow. 
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Table 11 All Cooperative Vessel Traffic Service (CVTS) vessel transits in 2009. For transits in OCNMS, the 

cumulative time and average transit time in OCNMS for all vessels of a given classification 

combined is provided for each vessel class.

Vessel Classification Total 

Transits

OCNMS 

Transits

Cumulative

Time (minutes)

Cumulative

Time (days)

Avg Time 

(hours)

Commercial Vessel < 300 GT 354 249 49,272 34.2 3.3

Commercial Vessel 300-1599 GT 246 65 14,229 9.9 3.6

Commercial Vessel > 1600 GT 6,449 4,272 403,534 280.2 1.6

Fishing Vessel < 300 GT 915 243 37,927 26.3 2.6

Fishing Vessel 300-1599 GT 146 63 11,814 8.2 3.1

Fishing Vessel > 1600 GT 125 81 15,431 10.7 3.2

Passenger Vessel < 300 GT 15 14 1,208 0.8 1.4

Passenger Vessel 300-1599 GT 9 9 1,170 0.8 2.2

Passenger Vessel > 1600 GT 451 280 20,727 14.4 1.2

Public Vessel < 300 GT 42 16 3,064 2.1 3.2

Public Vessel 300-1599 GT 227 75 14,926 10.4 3.3

Public Vessel > 1600 GT 291 157 24,912 17.3 2.6

Recreational Vessel < 300 29 13 1,454 1.0 1.9

Recreational Vessel 300-1599 42 36 3,813 2.6 1.8

Tank Vessel 1,734 1,401 209,360 145.4 2.5

Tug with tank barge-laden 104 94 29,447 20.4 5.2

Tug with tank barge-unladen 100 95 21,568 15.0 3.8

TOTAL 11,279 7,163 863,856 599.9 2.0

As part of the agreement, Tofino Traffic in Canada provides CVTS coverage for the offshore 

approaches to the Strait of Juan de Fuca and along the Washington State coastline from 

48 degrees north. Seattle Traffic in the U.S. provides CVTS coverage for both the Canadian and 

US waters of Strait of Juan de Fuca (http://www.uscg.mil/d13/cvts/purposeandobjective.asp). In 

addition to the marine communications and traffic services provided by the Canadian Coast 

Guard, the main features of the CVTS within the boundaries of the sanctuary are a number of 

International Maritime Organization (IMO) vessel routing measures. These include a traffic 

separation scheme with western and south-western approaches, a recommended route for 

smaller, slower moving vessels that normally do not use the traffic separation scheme, and an 

Area to be Avoided (ATBA) (Figure 8).

When the sanctuary was designated in May 1994, NOAA worked with the U.S. Coast Guard to 

propose that the IMO approve and adopt an ATBA off the Olympic Coast. This ATBA, which 

went into effect in June 1995 and was updated in 2002, advises operators of vessels above 

1600 gross tons and those carrying petroleum and hazardous materials as cargo to maintain a 

25-mile buffer from the coast. This distance narrows as the vessel traffic lanes converge at the 

entrance to the Strait of Juan de Fuca. It is important to note that the boundaries of the ATBA 
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and of the Sanctuary are not contiguous. The ATBA compliance rate has consistently been very 

high and was estimated to be 98.9% in 2009 (WDE 2010). OCNMS works with the USCG to 

notify non-compliant vessels with a formal letter requesting that they adhere to the ATBA in the 

future.

Figure 8 Vessel traffic management system

Just as marine transportation forms a vital economic link for Pacific Rim trade, the sanctuary 

forms a vital link among resource management agencies, enforcement organizations and the 

maritime transportation industry.
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6.4.3 Commercial Fishing

Commercial fisheries within the sanctuary are major components of the coastal economy and 

provide valuable food resources to the Northwest and beyond. Commercial and tribal fishers, as 

well as the business supporting these fisheries, are significant stakeholders in the health of the 

fisheries. 

The commercial fishing industry in Washington state is structured around a multi-species 

fishery. Groundfish, halibut, albacore, salmon and shellfish are all major species groups 

important to the industry. In 2006, non-tribal commercial fishing generated nearly $100 million 

in personal income and supported over 3,500 direct and indirect jobs in Washington state. These 

figures include only fisheries conducted off the coast of Washington and do not include 

commercial fishing by Coastal Treaty Tribes. When these segments are added, the harvest value 

is nearly $150 million. Though not directly correlated to the boundaries of the OCNMS, the 

Washington coast accounted for over 60% of the harvest value of commercial fisheries in 2006. 

Including in-state processing, the wholesale value of fishery products caught in Washington 

waters was an estimated $101 million in 2006 (WDFW 2008a).

Relative to uses of the OCNMS, commercial fishing activity can be described in two categories: 

commercial fishing vessels transiting through the area on way to their fishing grounds, home port 

or to another port for services; and those conducting operations in the sanctuary. Commercial 

fishing activity in the sanctuary includes both tribal and non-tribal fleets. The Makah, Quileute 

and Quinault fishers work respectively from the ports of Neah Bay, La Push and Grays Harbor. 

The Hoh Tribe does not currently have an ocean fishing fleet. Non-tribal fishermen work out of 

both Oregon and Washington ports. 

Some groundfish species have been depleted in the past and have recovered quickly (e.g., 

English sole, Pacific whiting, and lingcod), while others are rebuilding more slowly (e.g., Pacific 

ocean perch) (PFMC 2008a). For depleted species, rebuilding programs are in place, with 

anticipated stock recovery period from several to over 80 years for different species. All species 

considered depleted are on track to be rebuilt by their respective schedules, which take into 

account their different life histories. Recent fishery management measures implemented to 

reduce fishing effort, monitor and minimize bycatch, and reduce impacts to habitat appear to 

have assisted initial recovery of some overfished groundfish stocks and provide evidence for an 

improving trend. 

There are some indications the biomass off Washington of several rockfish species is high (per 

unit area) compared to Oregon and California, and this information has been taken into account 

for the management of some stocks (e.g., black rockfish). Survey data collected during NMFS

trawl surveys have not been quantitatively analyzed to determine if other groundfish stocks off 

Washington or in the sanctuary are more abundant than those off Oregon and California. 

The commercial Dungeness crab fishery has over 200 Washington coastal commercial 

Dungeness crab license holders. Dungeness crab landing data back to 1950 shows a large 

fluctuation in landings, averaging 4,300 metric tons (9.5 million pounds) per year, with 

variability likely due to varying ocean conditions including water temperature, food availability 

and ocean currents. A fishery for pink shrimp off Washington peaked in 1988, with landings just 
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over 18 million pounds and about 100 vessels involved. Within a few years, a dramatic decline 

in local abundance drove many fishers out of the fishery. Since 2000, the Washington coastal 

fishery has been stable, with landings of seven to eight million pounds annually and about 

25 fishers participating. Most shrimp and crab fishing occurs off the central and southern coast 

of Washington.

The Pacific halibut female spawning biomass is estimated at three to four times above the 

historical minimum in the mid-1970s, indicating that the halibut population is in good condition 

(NMFS 2004). Catch limits in Area 2A (Washington, Oregon and California) for commercial, 

treaty and recreational halibut fishing are approximately double limits imposed in the early 

1990s.

Chinook and coho salmon are the main salmon species managed by PFMC and American Indian 

tribes off Washington‟s outer coast. In odd-numbered years, fisheries are also conducted near 

the Canadian border for pink salmon, which are primarily of Frasier River origin. Managing 

ocean salmon fisheries is an extremely complex task, due to the wide oceanic distribution of the 

salmon, wide variability and difficulty in estimating population sizes, and significant differences 

between model estimates and actual returns. In the past decade, landings from the ocean troll 

fishery off Washington (excluding the area south of Willapa Bay) varied five-fold for chinook 

and nine-fold for coho between low and high catch years, but no clear trends in landings are 

evident (PFMC 2008b). Salmon at all life history stages are affected by a wide variety of natural 

and human-caused factors in the ocean and on land, including ocean and climatic conditions, 

habitat degradation and loss, and predators (including humans). Other challenges to a 

sustainable salmon fishery off the Washington coast include judging the effects of different 

regional fisheries on salmon stocks, recovering salmon under the Endangered Species Act, 

dividing the harvest fairly, impacts from salmon aquaculture, competition between wild and 

hatchery salmon, and restoring freshwater habitat (PFMC 2008b). 

Fisheries management policies enacted on the West Coast and within the sanctuary have been 

progressive steps to incorporate ecosystem-based fishery management concepts and improve 

trends toward restoring historical population levels. A variety of recent fishery management 

actions off the Washington coast, such as trawl footrope gear restrictions, low-rise nets that 

reduce bycatch, monitoring of bycatch, protection of Essential Fish Habitat, implementation of 

stock rebuilding plans, and establishment of temporary area closures (Rockfish Conservation 

Areas) to promote recovery of species under rebuilding plans, have provided early indications 

that depleted stocks can recover and these fisheries can be sustainably practiced. OCNMS‟ role 

in this management regime has been development of detailed seafloor habitat maps and 

participating in evaluation of essential fish habitat designations for groundfish.

6.4.4 Developed Environment

The shoreline and submerged lands of the sanctuary are largely undeveloped, but there are a 

number of manmade structures that do exist within or immediately adjacent to the sanctuary.

The La Push harbor at the mouth of the Quillayute River is the only port immediately adjacent to 

the sanctuary. The La Push marina is managed by the Quileute Tribe and supports their tribal 

fishers, as well as other non-tribal commercial and recreational fishers. The entrance to the 

harbor is maintained by the U.S. Army Corps of Engineers (USACE) as part of the Quillayute 
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River Navigation Project. Activities related to this project include the maintenance of the 

entrance channel, the boat basin and a protective jetty (USACE 2009). OCNMS regulations 

include an exception to allow for continued harbor maintenance associated with this project 

(15 CFR 922.152(a)(4)(iv).

There are several submarine cables that have been installed within the sanctuary, many of which 

were in place at the time OCNMS was designated in 1994. Since 1994 three fiber optic cables 

have been installed in the sanctuary (Figure 9). When OCNMS was studying the recovery of the 

seafloor habitat following the 1999 installation of the two Pacific Crossing cables (PC-1), 

sections of the cables were found to be exposed and suspended above the seafloor. In response 

to concerns about long-term cable integrity and conflicts with fisheries, PC-1 cables were 

recovered throughout the sanctuary and reinstalled in 2006 in an effort to comply with permit 

conditions, minimize risk to the cables, and reduce conflicts with fisheries.

Figure 9 Location of the Alaska United and Pacific Crossing fiber optic cables
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There are several year round and seasonal buoys within OCNMS, primarily navigational aids and 

monitoring/research buoys. The U.S. Coast Guard maintains navigational aids within the 

sanctuary; the National Data Buoy Center maintains weather observation platforms; and various 

agencies and academic institutions deploy research moorings.

In today‟s world, there is evolving and expanding interest in development of coastal marine 

waters, supported by technological advancements and in response to emerging social and 

economic needs. While current managers may not be able to anticipate development that might 

be proposed a decade or two in the future, access to physical forces in the ocean has emerged as 

development feasible in the immediate future as a source of renewable energy from a domestic 

source, without combustion of fossil fuels and exacerbation of climate change impacts. In fact, 

Makah Bay in OCNMS was the site of the first federal license issued to an ocean energy project 

intended to supply the public electricity grid. Beginning in 2000, AquaEnergy sought 

partnerships for the Makah Bay Wave Energy Pilot Project and was successful in gaining interest 

and agreements with several groups, including the Clallam County Public Utility District in 

Washington State and the Makah Tribe. Finavera Renewables, Inc. acquired AquaEnergy in 

May 2007, and the Federal Energy Regulatory Commission issued the first ocean energy license 

in the U.S. to this project in December 2007. Finavera eventually rescinded this license, and the 

pilot project was never constructed. From a resource protection perspective, this project was a 

challenge to OCNMS during this FEC licensing process for several reasons. At the time when 

OCNMS was required to define environmental concerns and monitoring requirements to 

evaluate potential natural resource impacts, no functional wave energy buoys of similar design 

had ever been constructed and field tested. Data for environmental impacts of similar projects 

anywhere in the world was sparse. Specifications for design of anchors, cables and power 

transmission lines had not been developed. In addition, this project was a new example of 

tradeoffs between potential localized environmental impacts and development of the ocean for 

renewable energy and, perhaps, sustainable human habitation of the planet. It is likely that 

consideration of similar projects and similar tradeoffs will be in the future for ONMS. 

6.4.5 Department of Defense Activities

In or adjacent to the sanctuary, the military has pre-established surface and subsurface ocean 

operating areas, including two warning areas (W-237A and W-237B) and two military operation 

areas (MOAs Olympic A and B) that are identified in OCNMS regulations (Figure 10). Military 

activities in these areas consist of subsurface, offshore surface, aerial training activities, and 

other military operations, which were described in general terms in the sanctuary‟s original 

environmental impact statement (NOAA 1993) and have been analyzed in more detail in recent 

Navy NEPA documents (U.S. Navy 2010a and b). 

Whereas OCNMS regulations include several prohibited activities (15 CFR 922.152(d)), they

also provide an exception for the following military activities within W-237A, W-237B, and 

MOAs Olympic A and B:

 Hull integrity tests and other deepwater tests

 Live firing of guns, missiles, torpedoes and chaff

 Activities associated with the Quinault Underwater Tracking Range, including the inwater testing of non-explosive torpedoes

 Anti-submarine warfare operations
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Figure 10 Military Operating Areas

Navy activities associated with technology research, development, testing and evaluation

conducted in the Quinault Underwater Tracking Range (QUTR), and fleet training exercises in 

the Northwest Training Range Complex (NWTRC) recently have been described in considerable 

detail, and their potential effects evaluated in separate environmental impact statements (EIS) via 

the National Environmental Policy Act (NEPA) process. The Navy‟s Underwater Warfare 

Center (NUWC) Division Keyport operates and maintains the QUTR located in Navy Operations 

Area W-237A. The Navy has conducted underwater testing at the QUTR since 1981 and 

maintains a control center at the Kalaloch Ranger Station. This range is instrumented to track 

and test surface vessels, submarines and various undersea vehicles. Research work involves 

testing of equipment and technologies, including mobile targets, torpedoes, underwater mine 
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shapes, and autonomous vehicles. The Navy has proposed expansion of this range‟s area more 

than 50-fold to support existing and future needs in manned and unmanned vehicle programs 

development (U.S. Navy 2010a). The preferred alternative in the final EIS expands this range‟s 

boundaries to coincide with the existing W-237A Military Warning Area boundary and adds a

surf-zone access site at Pacific Beach (Figure 10). To minimize cetacean disturbance, it is the 

policy of NUWC Division Keyport not to test when cetaceans are known to be present. The 

Navy was issued a Letter of Authorization under the Marine Mammal Protection Act (MMPA)

for use of sound sources for Keyport activities in May 2011. The Navy does not plan to expand 

any permanent bottom-mounted instrumentation, but has proposed temporary (up to two years) 

installations on the seafloor. In its comments during EIS development in consultation with Navy 

representatives, OCNMS requested avoidance of hard substrate areas that might support biogenic 

habitat and minimization of military expendable materials use. 

Navy fleet training activities were evaluated under a separate NEPA process that addressed the 

Northwest Training Range Complex that covers large areas of the ocean off Washington, Oregon 

and northern California (U.S. Navy 2010b). During scoping for these NEPA analyses, the 

OCNMS Advisory Council requested the NEPA analysis consider a wide variety of issues, 

including disturbance to birds, fish and mammals from increased activity and noise; damage to 

seafloor habitats and wildlife from cables, anchors, targets, torpedoes and unmanned undersea 

vehicles; accidental discharges of pollutants; interference with tribal fishing and subsistence 

harvest activities; and restrictions on the ability of sanctuary and affiliated scientists to conduct 

research. Within this area, the Navy conducts a variety of training activities, including antisurface warfare, anti-submarine warfare, electronic combat, mine warfare, strike warfare, and 

special forces training. The preferred alternative in the Navy‟s 2010 EIS included a relatively 

small percentage increase in use of various ordnances and expendables. In comments submitted 

during EIS development in consultation with Navy representatives, OCNMS raised concerns 

with impacts to disturbance-sensitive biogenic seafloor habitats and contributions to marine 

debris from military expendable materials, and requested development and use of biodegradable 

materials for expendable equipment. The Navy was issued a Letter of Authorization under the 

MMPA for use of sound sources for NWTRC activities in November 2010.

6.4.6 U.S. Coast Guard/Homeland Security Activities

The U.S. Coast Guard (USCG) protects U. S. coastlines by enforcing Federal law related to 

vessel safety, fishing, entry of illegal immigrants, drug trafficking and ocean dumping. The 

USCG also conducts search and rescue operations, assumes the lead in responding to spills of oil 

and hazardous waste into marine waters, and responds to complaints of improper conduct and 

vessel operation. USCG coverage of the sanctuary is shared by the 13th Coast Guard District‟s 

Sector Puget Sound and Sector Columbia River. 

Sector organization allows complementary Coast Guard assets to be coordinated under one 

command, focused on the primary areas of prevention and response. Sector Commanders fulfill 

a number of functions, such as Captain of the Port, Federal Maritime Security Coordinator, 

Federal On-Scene Coordinator, Officer-in-Charge of Marine Inspection, and Search and Rescue 

Mission Coordinator. Sector Puget Sound combines the legacy Vessel Traffic Service, Group, 

and Marine Safety Office into one consolidated organization with missions that include maritime 

safety, maritime security, protection of natural resources, maritime mobility and national 

defense.
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OCNMS also works closely with USCG Air Station/Sector Field Office Port Angeles, which is 

responsible for Neah Bay and Quillayute River Small Boat Stations; the 110-foot Patrol Boat 

USCGC Cuttyhunk; and seven 87-foot Patrol Boats. In addition, the Air Station/Sector Field 

Office Port Angeles maintains three MH-65C Dolphin short-range rescue helicopters. Certain 

activities carried out by the USCG necessary to respond to emergencies threatening life, 

property, or the environment, or necessary for law enforcement purposes are exempt from the 

prohibitions set forth in sanctuary regulations (15 CFR 922.152 (c) and (d)). However, other 

activities such as routine maintenance of aids to navigation and training exercises are not exempt 

from sanctuary regulations. Recognizing many of these routine activities as necessary to support 

OCNMS management objectives and ensure safe navigation at sea, the USCG and OCNMS have 

entered into a Memorandum of Agreement, which establishes a consultation process whereby 

USCG and OCNMS mutually agree upon procedures for conducting activities to support the 

sanctuary‟s mission that might otherwise be prohibited by sanctuary regulations. 

6.4.7 Recreational Fishing

Recreational fisheries within the sanctuary are major components of the coastal economy, 

providing valuable recreational opportunity and food resources to the Northwest and beyond. 

Recreational fishers, as well as the business supporting these fisheries, are significant 

stakeholders in the health of the fisheries. Recreational fisheries in the sanctuary include shorebased (surf casting, razor clamming and intertidal collection) and vessel-based activities 

managed primarily by Washington Department of Fish and Wildlife and Olympic National Park. 

In the entire state of Washington, recreational fishing, including finfishing and shellfishing, 

supported nearly 12,000 direct and indirect jobs in 2006, producing over $390 million in 

personal income in 2006. In 2006, recreational fishing in Washington state produced about 

$355 million in trip-related spending and $549 million in equipment expenditures, which 

includes the personal income generated. Of the jobs supported by recreational fishers, state 

residents accounted for more than 90 percent of the spending supporting these jobs (WDFW 

2008b).

Vessel-based recreational fishers typically operate in the sanctuary from marinas and boat launch 

ramps in La Push and Neah Bay, or farther afield in Westport and Seiku. The sanctuary overlaps 

WDFW marine management areas 2, 3, 4, and 4B. In 2009, nearly 100,000 angler trips were 

documented in these areas, of which about 60% were on private vessels and 40% on charter 

vessels (WDFW Ocean Sampling Program data). 

6.4.8 Recreation and Tourism

Over three million visitors are drawn to the Olympic Peninsula each year, attracted by beautiful 

scenery, the wilderness character of the landscape, spectacle of wildlife and the opportunity to 

challenge themselves in a natural environment. Many of these visitors reach the 65 miles of 

coastline the sanctuary shares with Olympic National Park. Nature viewing, hiking, camping 

and surfing are popular pursuits along this coastal wilderness strip. Wildlife watching is superb, 

with rewarding birding and whale watching opportunities available year round. In addition, 

Cape Flattery, on the Makah Indian reservation is the northwestern-most point in the lower 48 

United States, and a spectacular and very popular destination. 
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Most recreational boating in the sanctuary is sport fishers conducting day trips from the Neah 

Bay and La Push marinas. Other marinas supporting smaller vessels frequenting the sanctuary 

include Westport, Seiku and Snow Creek. Other recreational boating activity is associated with 

the non-consumptive uses such as diving, kayaking, wildlife viewing and sightseeing. Most 

recreational activity takes place during summer months, with recreational fishing largely 

concentrated around limited fishery openings managed by the Washington Department of Fish 

and Wildlife. Active water sports include sea and surf kayaking and surfing. Recreational use of 

OCNMS is not well characterized, but due to the remoteness and occasionally harsh conditions 

along the Olympic Coast, these recreational uses are relatively less common than in other coastal 

areas. A few dive charter operators serve the Olympic Coast, but ocean conditions and isolation 

require advanced skills and open-water experience.

Another recreational activity in the sanctuary is overflight from private pilots. An overflight is 

broadly defined as an aircraft (helicopter, plane, or other type of aircraft) that flies over sanctuary 

waters. Low overflights have the potential to cause wildlife disturbance. In order to protect 

nesting seabirds and marine mammals from disturbance from low flying aircraft, OCNMS has a 

regulation prohibiting aircraft from flying below 2,000 feet within one nautical mile of the 

shoreline or the offshore islands (15 CFR § 922.152(a)(6). Low overflights are the most 

frequently observed violation of sanctuary regulations. 

The socioeconomic importance of recreation and tourism on Washington‟s coastal communities 

is substantial. Statewide in Washington in 2008, travel and tourism generated over $14 billion in 

direct spending and over 145,000 tourism-related jobs, approximately 3 percent of all jobs and 2 

percent of all earnings in the state. Over 80 percent of 2008 traveler trips had some form of 

leisure or recreation as the main purpose of the trip, and over half of those trips focused on 

something other than visiting relatives or friends. While direct correlation of recreation and 

tourism spending to the national marine sanctuary cannot be determined, it is known travel and 

tourism generated over $1 billion in direct spending in the coastal region of the state. In 

addition, travel and tourism represent a much higher proportion of overall spending and 

employment in Washington‟s rural counties, including the coastal counties adjacent to OCNMS, 

than in urban counties (DOC 2009). 

6.4.9 Research and Monitoring

Characteristics identifying the Olympic Coast National Marine Sanctuary as a candidate for 

sanctuary designation also make it an important resource and site for scientific investigations. 

These characteristics include relatively undeveloped shoreline, high ecosystem productivity and 

high biodiversity. Research in the sanctuary is conducted by numerous governments, tribes, 

agencies and academic institutions for a variety of purposes. Much of this research is “basic” 

research to gain understanding of marine populations and systems, yet some efforts relate to 

resource management issues, such as fishery management. Emergent issues, such as hypoxic 

conditions and ocean acidification, are receiving increased attention, for which the sanctuary 

may become a focus area for research.

OCNMS‟ research program focuses on and supports scientific investigations to improve our 

understanding of the sanctuary‟s marine ecosystems and historical and cultural resources in order 

to provide managers with the information necessary to make informed decisions. In 2002, 

OCNMS staff and members of the Sanctuary Advisory Council drafted a Science Framework 
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document intended to guide the sanctuary in prioritizing and implementing a sound research and 

monitoring strategy.

OCNMS promotes and helps coordinate research programs in partnership with federal and state 

agencies, academia and tribal governments across multiple habitat ecosystems and 

geographic/oceanographic features. This includes accessible areas such as intertidal sites to 

more difficult monitoring locations, such as deep-sea environments and pelagic environments. 

OCNMS support for research and monitoring ranges from limited financial support to access to 

research vessels, either OCNMS or NOAA ships. Expertise from sanctuary staff is available, 

and logistical support is made available on a case-by-case basis. 

6.4.10 Education and Outreach

OCNMS is an important regional educational asset. It is used as a living classroom by many 

regional school groups and a training ground for many local educators. Part of the Sanctuary's 

mission is to organize and present educational resources reflecting what we know about this 

place. We strive to improve the understanding of future generations of citizens - students - now 

in school classrooms. We assist teachers educating tomorrow's scientists and endeavor to help 

people in local communities and around the globe see their role in enjoying and protecting the 

Sanctuary.

Education is essential in protecting marine sanctuaries. We teach the science of protecting 

marine resources. We encourage people who live both near and far from the ocean to take 

appropriate actions. We introduce young people to the skills required to become ocean citizens, 

perhaps even to pursue ocean–related careers.

Olympic Coast National Marine Sanctuary regularly conducts unique education events and 

programs as well as ongoing outreach events in communities throughout the region. Each 

OCNMS staff has expertise in some aspect of science, education and marine protection that is 

regularly shared through informative and current presentations on topics of local interest.

Olympic Coast Sanctuary education programs use a wide range of media to present information. 

We offer our services to teachers and students of all ages; we use the Internet, print media, video 

and other high-tech ways of presenting our messages. We also assist others, offering training to 

naturalists and accurate information to print and broadcast media. It has been said the greatest 

threat is not what we put into the ocean or take out of the ocean. The greatest threat to the seas is 

our ignorance, and our brightest hopes hinge on expanding our understanding.

6.4.11 Passive Users

Economists have long recognized a special class of non-market economic values for natural 

resources and the environment referred to generally as nonuse or passive use economic value. 

These values are widely accepted as legitimate values to include in benefit-cost analyses of 

environmental regulations and in damage assessment cases. The term passive use, instead of 

nonuse, has become more popular because it is recognized that for people to have value for 

something they must have some knowledge about what they are valuing. People learn about 

natural resources or the environment they are asked to value through books, newspapers, 

magazines, newsletters, radio, television and other media sources. The people do not actually 
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visit the sites and directly use the resources protected themselves, they consume them passively 

through the many indirect sources. The values have been referred to in the literature as option 

value, bequest value and existence value to clarify people‟s underlying motives for their 

willingness to pay. In other words, people have been shown to place a value on the ecological 

status and “health” of places they only know indirectly through various media and other 

channels, not through direct visitation or consumptive use.

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DESCRIPTION OF ALTERNATIVES

7 DESCRIPTION OF ALTERNATIVES

OCNMS staff has worked over the past 24 months with its Advisory Council (AC), the Olympic 

Coast Intergovernmental Policy Council (IPC) and the public to review and consider revisions to 

the current management plan for OCNMS. During this time, the IPC, AC and OCNMS staff 

held public meetings, formed working groups and held workshops to consider a variety of topics 

that needed to be addressed in the revised management plan. The AC, IPC and OCNMS staff 

reviewed and analyzed all of the recommendations that emerged. This detailed analysis resulted 

in the development of three alternatives to the proposed action. These alternatives are: 

1. A no-action alternative (alternative A) 

2. An alternative containing the strategies and activities (the Final Management Plan 

presented in section 5.0) that OCNMS staff, the AC and the IPC agree are priorities to 

meet the need for this action (alternative B)

3. An alternative containing several additional or modified activities to those presented in 

section 5.0 (alternative C). 

The preferred alternative (alternative B) is presented in full in section 5 as the final management 

plan. A summary of each alternative is provided in Table 12. 

Table 12 Summary of three alternatives analyzed

Alternative Description

alternative A 

(no action)

 No revisions or changes to original OCNMS 1994 management plan

 No changes to original OCNMS goals (there were no objectives identified in the 1994 management plan)

 No changes to OCNMS regulations

 No action plans or performance measures

 Continuation of existing OCNMS programs

alternative B 

(preferred)

 Set of 20 action plans presented in section 5 (Final Management Plan)

 Includes the revised goals and objectives presented in section 1.3

 Includes activities describing changes to regulations being proposed concurrent with the management 

plan review process

alternative C

 Set of 20 action plans presented in section 5 (Final Management Plan)

 Includes the revised goals and objectives presented in section 1.3

 Includes the regulatory changes described in alternative B, as well as the following actions:

- Evaluate options to make compliance with the ATBA mandatory,

- A regulatory ban of all large ship discharges (including cruise ships), excepting 1) vessels lacking

sufficient holding capacity for sewage and graywater, and 2) specific routine discharges necessary 

for vessel operation.

- A regulatory ban on the discharge of invasive species in the sanctuary

- A regulatory change that would reduce the overflight floor over the sanctuary from 2000 feet to 

1000 feet
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DESCRIPTION OF ALTERNATIVES

Regulatory changes ONMS proposed in alternatives B and C were included as activities in 

relevant action plans, and the environmental consequences of these regulatory changes are 

analyzed, as required under NEPA, in section 8 of this document. These changes to OCNMS 

regulations involved a federal rulemaking process separate from the adoption of a revised 

management plan but these processes ran concurrently. Proposed regulatory changes were 

published in a Federal Register notice with its own public comment period (76 FR 2611 and 

76 FR 6368).

7.1 ALTERNATIVE A (NO-ACTION ALTERNATIVE)

The no-action alternative (alternative A) would be to adopt the current OCNMS management 

plan – without revision – as OCNMS‟ management plan for the next five to ten years. This 

management plan (OCNMS1993) was published in 1993 and officially adopted in 1994 at the 

time of sanctuary designation (it is therefore referred to as the 1994 management plan). It was 

OCNMS‟ first management plan and dates from the time of sanctuary designation. Under the no 

action alternative, there would be no changes made to the 1994 management plan: no changes to 

existing OCNMS regulations, no changes to the existing OCNMS goals (there are no objectives 

in the 1994 management plan), and no inclusion of any additional information (such as the 

performance measures, cost estimates, budgets, action plans included in alternatives B and C).

The 1994 management plan broadly outlines the resource protection, research, education, 

administrative and visitor services necessary at the time of the sanctuary‟s designation. The 

focus of this management plan was on the initiation of sanctuary research, education and 

protection programs. Because this management plan was written at the time of sanctuary 

designation, when OCNMS staff and programs were emerging, the guidance provided in the 

1994 management plan is purposefully general in nature. It does not specifically address cultural 

resources, local and customary knowledge or the socioeconomic values of resources in the 

sanctuary, but it does not prohibit work on these topics. 

Because the 1994 management plan is written so broadly, any of the non-regulatory actions 

(administrative, resource protection, research, education and outreach, visitor services, maritime 

heritage) detailed under alternatives B and C (i.e., in the 20 action plans) could conceivably be 

implemented under alternative A (no action) – even though alternative A does not include these 

action plans. ONMS does not believe the no-action alternative would adequately address the 

purpose and need for revising the management plan. Because extensive efforts in collaboration 

with multiple partners were made through the management plan review process to evaluate 

OCNMS programs and more clearly define future priorities, it is likely that non-regulatory 

actions in alternative B would be implemented under the no action alternative. Thus, in the 

Environmental Consequences discussion (section 8.0), the environmental and human effects of 

non-regulatory actions in alternative A are addressed through analysis of alternatives B and C. 

The environmental and socioeconomic consequences of alternative A are analyzed in section 8.0 

of this document. 
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DESCRIPTION OF ALTERNATIVES

7.2 ALTERNATIVE B (PREFERRED ALTERNATIVE)

The preferred alternative (alternative B) is adopted as the Final Management Plan (FMP) 

presented in section 5.0 of this document in place of the 1994 OCNMS management plan. The 

FMP is comprised of 20 action plans organized under five of the six priority issues described in 

section 4.0 (priority management need one – treaty trust responsibility – does not encompass 

action plans per se, but is discussed in detail in section 2.0):

1. Treaty Trust Responsibility

2. Achieve Effective Collaborative and Coordinated Management

3. Conduct Collaborative Research, Assessments and Monitoring to Inform EcosystemBased Management

4. Improve Ocean Literacy

5. Conserve Natural Resources in the Sanctuary

6. Understand the Sanctuary‟s Cultural, Historical and Socioeconomic Significance

The action plans describe the work OCNMS staff would undertake over the next five to ten 

years, which includes both regulatory and non-regulatory activities. There are several regulatory 

changes associated with alternative B, and they will be issued in the same timeframe as the FMP. 

These regulatory changes, which include technical clarifications to the OCNMS regulations and 

a ban on cruise ship discharges, are noted in the relevant action plans and their impacts are 

analyzed in section 8.0 (Environmental Consequences). All regulatory changes are proposed as

a separate rulemaking process and will be announced in the Federal Register. OCNMS is 

synchronizing the rulemaking and management plan review processes to streamline these efforts; 

and this EA will be used to support both processes.

Each action plan is comprised of a series of strategies and activities both regulatory and nonregulatory in nature. In addition to the 20 actions plans, the FMP contains cost estimates for 

each strategy, a suite of performance measures by which OCNMS would evaluate its 

effectiveness in implementing the management plan, and an implementation table showing the 

level of priority (high, medium, low) for each strategy under three budget scenarios: a levelfunded budget, a moderately-increased budget and a substantially-increased budget. Alternative 

B provides substantially more detail about the work OCNMS will undertake than does the no 

action alternative A, which provides only broad descriptions of OCNMS program areas. 

Moreover, by including performance measures, cost estimates and an implementation plan, 

alternative B will create a high level of accountability not provided under alternative A. 

Alternative B, in addition to encompassing all the actions proposed in section 5.0 (Final 

Management Plan), also includes the revised OCNMS goals and objectives presented in 

section 1.3. These goals and objectives replace the goals in the original 1994 management plan.

Alternative B (preferred) is the alternative that best meets the purpose and need for revising the 

OCNMS management plan. Alternative B and the 20 action plans it encompasses address all of 

the primary needs identified, including:
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DESCRIPTION OF ALTERNATIVES

 Updating an out-of-date management plan

 Addressing recent changes in regional ocean governance

 Filling data gaps

 Incorporating new technologies

 Addressing issues that have emerged over the past 16 years

Moreover, the suite of regulatory and non-regulatory activities in alternative B address these 

needs in a manner best complementing the existing programs, policies and regulations of 

OCNMS‟ key ocean management and conservation partners in the region. Over 100 regional 

experts were involved in developing and refining the action plans presented in alternative B. 

These action plans identify a clear and precise role for OCNMS in each of the 20 topic areas they 

cover – a role that would not duplicate the efforts of others and would provide for the most 

effective use of OCNMS‟ limited resources. 

The environmental and socioeconomic consequences of alternative B are analyzed in section 8.0 

of this document. 

7.3 ALTERNATIVE C (NOT PREFERRED)

Alternative C is based on alternative B (preferred) by adopting the FMP (and 20 its action plans) 

presented in section 5.0, but with modifications to specific action plans and strategies. The 

modifications included in alternative C follow:

1. In the Spills Prevention, Preparedness, Response and Restoration Action Plan, Strategy 

SPILL1: ATBA Management, Compliance and Monitoring would be modified to 

include the following new non-regulatory activity:

“Work collaboratively with other Federal agencies and the International Maritime 

Organization (IMO) to evaluate options to make compliance with the ATBA mandatory.”

Currently, the Olympic Coast ATBA is an International Maritime Organization (IMO)

voluntary vessel routing measure. Under alternative B (preferred), it would remain 

voluntary and ONMS would work with the USCG to prepare a proposal to the 

International Maritime Organization Subcommittee on Safety of Navigation to pass 

implementing legislation requiring that “restrictions apply to all vessels required to 

prepare a response plan pursuant to Section 311(j) of the Federal Water Pollution Control 

Act (33 U.S.C. 1321(j)) (other than fishing or research vessels while engaged in fishing 

or research within the area to be avoided)” (Section 704, Coast Guard Authorization Act 

for Fiscal Years 2010 and 2011). The ATBA does not apply to public vessels, or vessels 

owned or chartered and operated by the United States, or by a State or political 

subdivision thereof, or by a foreign nation, except when the vessel is engaged in 

commerce.

Currently, compliance with the ATBA is voluntary and, under Alternative B (preferred), 

it would remain voluntary. Under alternative C, ONMS would work with its partners

over the next five to ten years to evaluate options to make the ATBA mandatory. 

Options considered included both domestic federal regulations under the authority of the 
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DESCRIPTION OF ALTERNATIVES

USCG (i.e., Port and Waterways Safety Act) and the ONMS (i.e., National Marine 

Sanctuaries Act), and IMO vessel routing measures under the authority of the United 

Nations Convention on the Law of the Sea.

Under Alternative C, ONMS would not immediately pursue domestic or international 

regulatory changes, but would work during the management plan implementation process 

(i.e., over the next five to ten years) to develop a new regulation(s) that mandates 

compliance with the ATBA. Once a proposed regulatory change is agreed upon, it would 

go through its own separate process. 

Interest in strengthening the ATBA has come up repeatedly since its original adoption in 

1994. In 2002 ONMS, working with the USCG and the IMO, modified the original 

provisions based on the results of a USCG Port Access Routes Study completed in 2000

(USCG 2000). This study evaluated the need for modifications to vessel routing and 

traffic management measures in the Strait of Juan de Fuca and adjacent waters, including 

the sanctuary. Recommendations included three that applied to sanctuary waters: (1) a

proposal to amend the IMO-adopted ATBA off the Washington Coast to increase its size 

and extend its applicability to commercial ships of 1,600 gross tons and above; (2) a

proposal for recommended routes in the United States waters of the Strait of Juan de Fuca 

for smaller, slower moving vessels that normally do not use the traffic separation scheme; 

and (3) a proposal amending the existing traffic separation schemes (TSSs) in the Strait 

of Juan de Fuca and its approaches (66 F.R. 6514). All 3 proposals were approved by the 

International Maritime Organization in May 2002 (67 F.R. 70933).

Interest in strengthening the ATBA was also expressed during the public scoping 

comment period for MPR and by a member of the public during a public comment period 

at an AC meeting. In 2007 the Washington State Oil Spill Advisory Council requested 

that OCNMS consider extending ATBA applicability to cover unladen oil barges (which 

carry some residual oil). Similar concerns recently led Senator Maria Cantwell (WA-D) 

to include provisions in legislation to strengthen the ATBA through expansion of the 

vessels covered by this voluntary measure (Section 704, Coast Guard Authorization Act 

for Fiscal Years 2010 and 2011). Given a hazardous spill is perhaps the most significant 

threat to resources in the sanctuary, it is reasonable to consider an alternative that 

strengthens the ATBA. 

The Advisory Council working group focused on Spills Prevention, Preparedness, 

Response and Restoration did not consider a recommendation to strengthen the ATBA 

because the current voluntary ATBA has such a high compliance rate (98.9% compliance

in 2009, WDE 2010). For this reason the alternative to consider mandatory compliance 

to the ATBA was not included in OCNMS‟ preferred alternative. 

2. In the Wildlife Disturbance Action Plan, Strategy WD2: Overflight Restriction Zone 

would be modified to include the following regulatory activity:

“During the management plan review process, modify OCNMS regulations to reduce the 

overflight floor over the sanctuary from 2,000 feet to 1,000 feet.” 
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DESCRIPTION OF ALTERNATIVES

This new activity would represent a change to OCNMS regulations not proposed under 

alternative B (preferred). Under alternative B (preferred) the overflight floor (minimum 

altitude) would remain at 2,000 feet. 

Of the four West Coast sanctuaries with overflight regulations, OCNMS is the only one 

with a 2,000 foot overflight regulation; the other three sanctuaries have a 1,000 foot 

overflight regulation. Existing literature suggests a 1,000 foot restriction is generally 

adequate to protect wildlife. However, the Federal Aviation Administration (FAA) has a 

policy for noise-sensitive areas recommending a 2,000 foot minimum altitude over 

national parks and wildlife refuges (FAA AC 91-36d), such as Olympic National Park 

(ONP) and the Washington Maritime National Wildlife Refuge Complex (WMNWRC), 

the jurisdictions of which overlap with the sanctuary. This FAA policy is advisory in 

nature and is not enforceable. The current OCNMS regulation was established for 

consistency with this advisory. In recent years, OCNMS staff has been considering the 

possibility of reducing the overflight regulation from 2,000 to 1,000 feet because it is less 

restrictive to the public and could still meet the objective of protecting wildlife in the 

sanctuary. 

This alternative is not preferred because, while lowering the elevation is not expected to 

have significant adverse impacts on wildlife in the sanctuary, it is not expected to 

improve resource protection for wildlife. In addition, the aesthetic climate of the 

wilderness coastline of ONP could be degraded by lowering the enforceable minimum 

altitude for overflights. Moreover, changing OCNMS‟ overflight regulation in this way 

would make it inconsistent with overflight advisories over adjacent National Park Service 

and U.S. Fish and Wildlife lands, which might lead to confusion for pilots.

3. In the Water Quality Protection Action Plan, Strategy WQP1: Vessel Discharges, 

Activity B (cruise ship discharge regulatory ban) would be revised to state:

Activity B: During the management plan review process, modify OCNMS regulations to 

prohibit:

 all discharges from cruise ships into waters of the sanctuary except clean vessel 

engine cooling water, clean vessel generator cooling water, clean bilge water, 

anchor wash. (existing language for alternative B)

 all discharges (except when limited by sewage or graywater holding capacity) 

from vessels 300 gross tons and above into waters of the sanctuary, except clean 

vessel engine cooling water, clean vessel generator cooling water, clean bilge 

water, anchor wash.

Under alternative B (preferred), this activity would be directed solely toward prohibiting 

cruise ship discharges. Under alternative C, this regulatory action would be expanded to 

address all vessels 300 gross tons and above for all discharges, with noted exceptions 

required for operations and vessels lacking sufficient holding tank capacity for sewage or 

graywater to hold effluent while within the sanctuary.
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DESCRIPTION OF ALTERNATIVES

Interest in water quality and the effects of vessel discharges (including cruise ship 

discharges) in the sanctuary were expressed during the MPR public scoping period and 

during subsequent public comment periods at AC meetings. The Living Resource 

Conservation Working Group‟s findings to the Advisory Council recommended a 

regulatory prohibition on cruise ship discharges in OCNMS and several non-regulatory 

activities to address other discharge concerns. OCNMS staff considered a broader 

prohibition of discharges from additional vessel classes. Prohibiting all discharges from 

large vessels in the sanctuary would be consistent with the NMSA‟s primary objective of 

resource protection and could meet the need to update the 1994 management plan to 

reflect the development of issues since the publication of the 1994 management plan. A 

discharge ban on all large vessels would reduce the volume of wastewater discharged to 

the sanctuary and would avoid singling out one industry (i.e., cruise ship) in the analysis.

This is not the preferred alternative for addressing vessel discharges because vessels other 

than cruise ships generate a proportionally smaller discharge volume relative to that 

generated by cruise ships. Cruise ships carry many passengers, whereas most other large 

vessels traversing or working in the sanctuary have relatively small crews and thus do not 

generate nearly the volume of discharges that cruise ships do. 

Given the current knowledge on vessel discharge impacts to the marine environment and 

the existing state of Washington regulation prohibiting all vessel discharges within three 

miles of the shoreline, NOAA believes eliminating discharges from cruise ships in the 

sanctuary would provide ample protection of sanctuary resources at this time. 

Additionally, there are specific, non-regulatory actions proposed in the actions plans 

under alternative B addressing additional discharges.

4. In the Habitat Protection Action Plan, Strategy HP3: Invasive Species would be 

modified to include the following new activity:

“During the management plan review process, modify OCNMS regulations to ban the 

discharge of invasive species in the sanctuary.”

ONMS defines the term “invasive species” according to the state of Washington Invasive 

Species Council definition, “invasive species include non-native organisms that cause 

economic or environmental harm and are capable of spreading to new areas of the state. 

Invasive species does not include domestic livestock, intentionally planted agronomic 

crops, or non-harmful exotic organisms." The Washington Invasive Species Council 

maintains an updated list of invasive species (aquatic and terrestrial) for the state of 

Washington. OCNMS would implement this regulation according to the most current 

version of this list.

It should be noted several of the national marine sanctuaries in California implemented 

similar regulatory bans, but these sanctuaries banned introduction of introduced (not 

invasive) species and defined introduced species as, “any species (including but not 

limited to any of its biological matter capable of propagation) that is non-native to 

ecosystems of the sanctuary; or any organism into which altered genetic matter, or 

genetic matter from another species, has been transferred in order that the host organism 
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DESCRIPTION OF ALTERNATIVES

acquires the genetic traits of the transferred genes.” ONMS has chosen to use the 

Washington Invasive Species Council definition of invasive species so an OCNMS 

discharge ban on invasive species would complement and be consistent with state of 

Washington efforts toward invasive species. Additionally, the Washington Invasive 

Species Council has formal, established and scientifically supported procedures for 

identifying which species meet their definition. This Council regularly updates and 

refines this list as necessary. Thus, OCNMS, in using the council‟s definition, would also 

be able to use and refer sanctuary users to the State‟s list of invasive species. Using the 

state‟s list of invasive species would reduce confusion for sanctuary users trying to

adhere to both state and OCNMS invasive species regulations.

This new management plan activity would represent an additional change to OCNMS 

regulations that is not proposed under alternative B (preferred). Under alternative B there 

would be no regulatory changes related to the discharge of invasive species.

Concern about preventing the introduction of invasive species was expressed during the 

MPR public scoping period. In particular, there was concern about the potential culture 

of invasive species in the sanctuary, such as Atlantic salmon, which is defined as a 

regulated invasive species by the Washington Invasive Species Council. While cultured 

species are regulated and have been managed in Washington waters for many decades,

some cultured species, such as Atlantic salmon, are known to have escaped culture pens 

and caused impacts to native species (Naylor et al. 2005).

The Living Resources Conservation Working Group and the Collaborative Research, 

Assessments and Monitoring Working Group of the Advisory Council both considered 

recommending actions to address the issue of invasive, non-native species. However, the 

Living Resources Conservation Working Group, after reviewing existing state and 

regional regulations and policies related to invasive species, concluded an OCNMS 

regulation related to invasive, non-native species was unnecessary. However, a

regulation to prevent the introduction of invasive, non-native species would be consistent 

with the NMSA‟s primary objective of resource protection, and it could meet the need to 

update the 1994 management plan to reflect issues arising since the publication of the 

1994 management plan. 

This alternative is not preferred, however, for several reasons:

 One of the primary vectors for invasive species introductions in the sanctuary is 

ballast water. The state of Washington has extensive ballast water regulations,

the aim of which is to prevent the introduction of invasive species 

(http://wdfw.wa.gov/fish/ballast/ballast.htm). These regulations are some of the 

strongest in the nation. These state regulations prevent the exchange of ballast 

water in or near sanctuary waters because vessels traveling into the U.S. from 

another country are required to exchange ballast water more than 200 nmi from 

shore, and vessels traveling along the U.S. coast must exchange ballast water 

further than 50 nmi from shore. OCNMS believes existing state regulations are 

an effective way to address this issue and banning the discharge of non-native 
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DESCRIPTION OF ALTERNATIVES

species would not strengthen protections already provided by WA state ballast 

water regulations. 

 The other primary vector for non-native species invasions into the sanctuary is the 

potential spread of invasive species from populations adjacent to the sanctuary 

(i.e., European green crab). A regulation would not address the potential 

movement or range expansion of existing invasive species into the sanctuary 

(unless a person was caught carrying a European green crab into the sanctuary, 

which is highly unlikely). The most effective strategy to address a range 

expansion of an invasive species is monitoring for their presence and working 

with partners to establish eradication plans.

 Another potential vector for introduction of invasive species would be an 

aquaculture facility within the sanctuary. However, there are currently no 

aquaculture facilities in the sanctuary, nor are any foreseen at this time. Any 

development of aquaculture within the sanctuary is unlikely due to dynamic ocean 

conditions of the outer Washington coast. Further, an aquaculture operation, 

which required a sanctuary permit due to seabed disturbance, discharge, or 

otherwise, would allow OCNMS to consider all the potential impacts of the 

operation, including potential impacts from the culture of invasive species. Thus, 

it is not necessary for OCNMS to enact a specific invasive species regulation of 

this nature. That being said, OCNMS should continue to stay abreast of 

aquaculture technology developments and, if necessary, revisit this issue during 

the next management plan review process. 

In addition to these four modifications, alternative C also encompasses the revised OCNMS 

goals and objectives presented in section 1. Should alternative C be selected, these goals and 

objectives would replace the goals in the original 1994 management plan.

The environmental and socioeconomic consequences of these modifications are analyzed in 

section 8 of this document. 

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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

8 ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

This section evaluates the environmental consequences of the proposed action of revising the 

Olympic Coast National Marine Sanctuary (OCNMS) management plan. Because each 

management plan alternative (described in section 7) is comprised of numerous smaller actions, 

the term “action(s)” is used in this section not only to reference the overall proposed action of 

revising the management plan but also to reference the smaller individual actions comprising

each alternative. 

The environmental effects of the no-action alternative (alternative A), the proposed management 

plan revision (alternative B-preferred), and alternative C are summarized (Table 13) and then 

evaluated within the context of the physical, biological, historic and cultural, and human and 

socioeconomic sanctuary setting. Information about the biological, physical, historic, cultural 

and socioeconomic sanctuary setting can be found in the Affected Environment discussion 

(section 6). 

Alternative A (no action) includes only non-regulatory actions (i.e., no changes to OCNMS 

regulations are proposed). Alternatives B and C are comprised of both non-regulatory and 

regulatory actions (i.e., they include proposed changes to existing OCNMS regulations). Both 

the regulatory and non-regulatory actions associated with alternatives B and C are analyzed in 

sections 8.1 through 8.4. Section 8.4 (effects to the historic and cultural setting) serves a dual 

purpose, fulfilling OCNMS‟ compliance requirements both under the National Environmental 

Policy Act (NEPA) and the National Historic Preservation Act (NHPA). Section 8.5 discusses 

the cumulative effects of the three alternatives within the context of other known activities 

occurring within the sanctuary region. 

Characterizing Effects

NEPA requires consideration of the effects of major federal actions on the quality of the human 

environment (42 U.S.C. 4332 (c)). Effects are characterized as negligible, less than significant 

or significant, and are also characterized by type (adverse or beneficial), context, intensity, 

duration (short- or long-term). Effects can be further characterized by whether they affect 

resources directly or indirectly. The following definitions and characterizations were used for 

this analysis:

 Negligible effects –effects for which virtually no effect to a resource can be detected 

(whether beneficial or adverse).

 Less than significant effects –effects that do not rise to the level of “significant” as 

defined below.

 Significant effects – effects resulting in an alteration in the health of a physical, 

biological, historic/cultural or socioeconomic resource. Long-term (see below) or 

permanent effects with a high intensity of alteration to a resource, whether beneficial or 

adverse, would be considered significant. The significance threshold is evaluated on a 

case-by-case basis, taking into consideration the context and intensity of each action. 

Context normally refers to the setting (e.g., the local and regional status of the resource 

being affected), and intensity refers to the severity of the effect. Significant effects can 

be adverse or beneficial, and direct or indirect. Consideration of the accumulation of
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

Table 13 Summary of analyzed actions

Action Alternative(s) That 

Contain This Action

Relevant Action 

Plans Effect of Action Resources Affected

Structural changes to the format of the OCNMS 

management plan, and revisions to OCNMS goals and 

objectives 

B, C All 20 Action Plans Negligible None

Routine office activities, including meetings, education, 

visitor and training programs that take place in existing 

OCNMS or other facilities

A, B, C All 20 Action Plans Negligible None

Use of Information Technology (includes internet 

technology, data management technology)

A, B, C All 20 Action Plans Negligible None

Routine outreach activities that do not occur in the 

sanctuary (fair booths, community events)

A, B, C All 20 Action Plans Negligible None

Routine education, outreach and visitor activities A, B, C ED, OUT, VISIT, 

HED, CLIM, MD, WD

Less than Significant, 

Beneficial, Indirect, Short-term

Biological, Physical, Historic and 

Cultural, Socioeconomic

Routine research activities A, B, C MAP, OCEO, ECO, 

DATA, SOCIO

Less than Significant, 

Beneficial, Indirect, Short-term

Biological, Physical, Historic and 

Cultural, Socioeconomic

Routine maritime heritage activities A, B, C MH Less than Significant, 

Beneficial, Indirect, Short-term

Historic and Cultural,

Socioeconomic

Routine resource protection and stewardship activities A, B, C SPILL, MD, CLIM, 

HP, WQP, ROP, WD

Less than Significant, 

Beneficial, Indirect, Short-term

Biological, Physical, Historic and 

Cultural, Socioeconomic

Routine administrative activities (enforcement of 

regulations and permitting)

A, B, C CCM, OPS, WD, 

WQP, HP, MH

Less than Significant, 

Beneficial, Indirect, Short-term

Biological, Physical, Historic and 

Cultural, Socioeconomic

Sediment sampling (for habitat mapping and 

community characterization)

A, B, C MAP, ECO Less than Significant, Adverse, 

Direct, Short-term

Biological, Physical, Historic and 

Cultural

Operating sonar (for hydrographic surveying) A, B, C MAP Less than Significant, Adverse, 

Direct, Short-term

Less than Significant, 

Beneficial, Indirect, Long-term

Biological, Physical

Historic and Cultural

Anchoring research buoys A, B, C OCEO Less than Significant, Adverse, 

Direct, Short-term

Biological, Physical, Historic and 

Cultural
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

Table 13 (continued) Summary of analyzed actions

Action Alternative(s) That 

Contain This Action

Relevant Action 

Plans Effect of Action Resources Affected

Operating vessels in sanctuary A, B, C OPS, MAP, OCEO, 

ECO,

Less than Significant, Adverse, 

Direct and Indirect, Short-term

Less than Significant, 

Beneficial, Indirect, Short-term

Biological, Physical

Socioeconomic

Conducting wildlife research, monitoring and 

assessments

A, B, C ECO Less than Significant, Adverse, 

Direct, Short-term

Biological

Beach and intertidal activities (student field trips, beach 

debris removal)

A, B, C ED, OUT, MD Less than Significant, Adverse, 

Direct, Short-term

Less than Significant, 

Beneficial, Indirect, Short-term

Biological, Physical

Socioeconomic

Encouraging visitor use of beaches and intertidal areas A, B, C VISIT Less than Significant, Adverse, 

Direct, Short-term

Less than Significant, 

Beneficial, Indirect, Short-term

Biological, Physical

Socioeconomic

Evaluate options to make compliance with the ATBA 

mandatory

C SPILL Less than Significant, 

Beneficial, Indirect, Long-term

Less than Significant, Adverse, 

Direct, Short-term

Biological, Physical,

Socioeconomic

Replace the term “traditional fishing” with “lawful 

fishing”

B, C OPS Negligible None

Technical clarifications to OCNMS regulations B, C OPS Negligible None

Modification of the tribal welfare permit provision B, C OPS Negligible None

Alteration of overflight regulation (reducing overflight 

floor from 2,000 feet to 1,000 feet

C WD Less than Significant, Adverse, 

Direct, Long-term

Physical, Socioeconomic

Including a new regulation to ban discharge of invasive 

species

C HP Less than Significant, 

Beneficial, Indirect, Long-term

Less than Significant, Adverse, 

Direct, Long-term

Biological, Physical

Socioeconomic
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

Table 13 (continued) Summary of analyzed actions

Action Alternative(s) That 

Contain This Action

Relevant Action 

Plans Effect of Action Resources Affected

Expanding discharge regulation to include ban on 

cruise ship discharge

B, C WQP Less than Significant, 

Beneficial, Indirect, Long-term 

Less than Significant, 

Beneficial, Direct, Long-term

Biological, Physical

Socioeconomic

Expanding discharge regulation to include ban on large 

vessel discharges

C WQP Less than Significant, 

Beneficial, Indirect, Long-term 

Less than Significant, Adverse, 

Direct, Short-term

Biological, Physical,

Socioeconomic
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

several individually less than significant effects could result in a determination of 

significance for cumulative effects.

 Adverse effects – effects negatively affecting the health of a resource.

 Beneficial effects –effects positively affecting the health of a resource.

 Short-term effects – effects lasting one year or less.

 Long-term effects – effects lasting longer than one year and/or potentially permanent.

 Direct effects – effects occurring at the same time and place as the action. 

 Indirect effects – effects occurring later in time or farther removed from the place where 

the action occurs, but reasonably foreseeable. 

 Cumulative effects – effects resulting from the incremental impact of an action when 

added to other actions in the past, present, or foreseeable future, regardless of who 

undertakes such action. 

Analysis of the environmental consequences of the three alternatives is based largely on review 

of existing literature and studies, information provided by experts, and best professional 

judgment. Environmental consequences of the proposed actions are considered within the 

context of the revised management plan‟s five to ten-year planning horizon. Thus, when 

assessing the effects of an action, the action is presumed to occur for, at most, ten years. In 

instances where the duration of effects for a specific action potentially repeated within the fiveto ten-year planning horizon may be longer than one year, the effects of the action(s) are 

analyzed as long-term and cumulative effects.

Action Plan (AP) Abbreviations:

CCM – Collaborative and Coordinated Management AP

COM – Community Involvement in Sanctuary Management AP

OPS – Sanctuary Operations AP

MAP – Habitat Mapping and Classification AP

OCEO – Physical and Chemical Oceanography AP

ECO – Populations, Communities and Ecosystems AP

DAT – Data Management, Sharing and Reporting AP

ED – K-12 Education AP

HED – Higher Education AP

VISIT – Visitor Services AP

OUT – Community Outreach AP

SPILL – Spills Prevention, Preparedness, Response and Restoration AP

CLIM – Climate Change AP

MD – Marine Debris AP

WD – Wildlife Disturbance AP

WQP – Water Quality Protection AP

HP – Habitat Protection AP

ROP – Regional Ocean Planning AP

MH – Maritime Heritage AP

SOCIO – Socioeconomic Values of Resources in the Sanctuary
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

8.1 PHYSICAL SETTING

The purpose of this section is to discuss the effects of all three alternatives on physical resources 

in the sanctuary. An overview of the sanctuary‟s physical setting and the resources encompassed 

within it is provided in the Affected Environment discussion (section 6.1).

8.1.1 Actions with Negligible Effects to the Physical Setting

There are several actions that would occur under all three alternatives expected to have a 

negligible effect on the physical setting. These actions include:

 Structural changes to the format of the OCNMS management plan, and revisions to 

OCNMS goals and objectives

 Routine office and classroom activities, including meetings, visitor, education and 

training programs taking place in existing OCNMS or other facilities

 Use of Information Technology resources, including internet technology, data 

management programs, phone and e-mail technology

 Routine outreach activities not occurring in the sanctuary, including staffing fair booths 

and attending community events

 Routine maritime heritage activities

 Conducting wildlife research, monitoring and assessments

These actions are expected to have a negligible effect on physical resources because these 

actions all occur within existing facilities, or no construction or physical development is 

anticipated to be required to conduct these actions. Additionally, these actions would not involve 

any direct or indirect interaction between the people and physical resources within the sanctuary. 

Another action proposed under alternatives B and C involves modifications to OCNMS 

regulations and also would have negligible effects on physical resources: 

 Replace the term “traditional fishing” with “lawful fishing”

 Modifications to the tribal welfare permit provision in the OCNMS regulations 

 Technical clarifications to OCNMS regulations as outlined in the Sanctuary Operations 

Action Plan (strategy OPS 9, activity H)

The current OCNMS regulations define the term “traditional fishing” as “using a fishing method 

that has been used in the sanctuary before the effective date of sanctuary designation (July 22, 

1994), including the retrieval of fishing gear” and provide an exception for traditional fishing 

operations to three of the regulatory prohibitions – prohibitions on discharge of certain fishingrelated materials, disturbance to historical resources and disturbance to the seabed. OCNMS 

regulations could be interpreted to mean fishing methods or operations not falling within the 

definition of “traditional fishing” are not allowed to discharge materials mentioned above, or 

disturb historical resources or the seabed. The precise language of these three exceptions is as 

follows:
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

 “Discharging or depositing, from within the boundary of the Sanctuary, any material or 

other matter except... fish, fish parts, chumming materials or bait used in or resulting 

from traditional fishing operations in the Sanctuary.” (15 CFR 922.152(2)(i))

 “Moving, removing or injuring, or attempting to move, remove or injure, a Sanctuary 

historical resource. This prohibition does not apply to moving, removing or injury 

resulting incidentally from traditional fishing operations.” (15 CFR 922.152(3))

 “Drilling into, dredging or otherwise altering the seabed of the Sanctuary; or 

constructing, placing or abandoning any structure, material or other matter on the seabed 

of the Sanctuary, except as an incidental result of... Traditional fishing operations.” 

(15 CFR 922.152(4)(ii))

As part of this action, NOAA is replacing the term “traditional fishing” with the term “lawful 

fishing” in these three places to: 1) use a term that is more clearly understood; and 2) eliminate 

the distinction between fishing methods used before OCNMS designation from those that have 

since been authorized. Despite the definition provided in the current OCNMS regulations, and 

because of its varied connotation, the term “traditional” in OCNMS regulations may be 

incorrectly interpreted (e.g., equating traditional fishing with Native American fishing 

techniques). Additionally, there is ambiguity associated with the extent of gear modification or 

uniqueness of design or practice constituting a new or non-traditional fishing method. By 

replacing the word “traditional” with “lawful” NOAA would unambiguously recognize fishing 

activities authorized by governmental fisheries management authorities. This change would also 

be consistent with terms used in the regulations for other national marine sanctuaries on the West 

Coast. 

In recent decades, findings of overfishing and habitat damage from fisheries in U.S. waters have 

led to gear modifications, mandated stock rebuilding plans, and emergence of an ecosystem 

approach to fishery management. Before they are authorized, new fishing techniques, gear 

modifications, or targeted species proposed to federal, tribal and state authorities are evaluated 

for habitat and ecosystem impacts. This work occurs on a regular basis. While many of the new 

fishery practices (e.g. gear modifications, rebuilding measures, etc.) are anticipated to have fewer 

impacts to sanctuary resources, it is possible that a new, lawful fishery or fishery practice may 

have a negative impact on sanctuary resources (e.g., a test fishery that has unanticipated 

impacts). In such cases, the proper way to address any concerns related to potential new 

fisheries or fishing methods within the sanctuary would be through the interagency consultation 

process pursuant to Section 304(d) of the NMSA (16 U.S.C. 1434(d)). 

This change is expected to have a negligible effect because Federal, state, tribal and regional 

fishery management authorities currently analyze and attempt to mitigate impacts associated 

with lawful fishing, including fisheries that have occurred traditionally in the sanctuary, and 

those authorities are expected to do the same in the future. Since the scope and impacts of any 

such future management actions are speculative at this point, it is not possible, and would be 

inappropriate, to speculate on any additional impact analysis of this change in this document.

Additional changes to OCNMS regulations identified in strategy OPS 9, activity H would not 

affect the physical resources within the sanctuary because the changes are language clarifications 

that do not alter the meaning or intent of the regulations. 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

Under the current regulations, ONMS can issue a permit to conduct an activity that would 

otherwise be prohibited if it finds that the activity will meet criteria identified in the regulations. 

The first criterion is the requirement that NOAA finds that the activity will not substantially 

injure Sanctuary resources and qualities. The second criterion is related to the purpose of the 

proposed activity. One of these purposes is the promotion of the welfare of any Indian tribe 

adjacent to the sanctuary. This provision is ambiguous and could be interpreted as allowing an 

entity not affiliated with a tribe to apply for a permit that it alleges could promote the welfare of 

an Indian tribe adjacent to the sanctuary. The concept of “promote the welfare of any Indian 

tribe” is not defined or explained further in the regulations, the terms of sanctuary designation, or 

the 1993 Final EIS. In the proposed rule (76 FR 2611), NOAA had further clarified the 

regulation by replacing the phrase “to promote the welfare of any Indian tribe adjacent to the 

Sanctuary” with “to promote or enhance tribal self-determination, tribal government functions, 

the exercise of treaty rights or tribal economic development.”

Based on government-to-government consultations with the Makah Tribe, NOAA has made 

further changes to the rule modification. NOAA clarified the ambiguity created by the proposed 

rule (76 FR 2611), making clear that either a Coastal Treaty Tribe (i.e. Hoh, Makah, and 

Quileute Indian Tribes and the Quinault Indian Nation) or its designee may apply for or be a coapplicant for a permit to promote or enhance tribal self-determination. The final rule language 

further clarifies that the governing body of the tribe must certify the tribal designee as applicant 

or co-applicant for a permit, but the tribe need not itself be the applicant or co-applicant. It is not 

the intent of this language to limit the persons or entities who may apply for a permit under this 

provision or to require an agency relationship between a tribe and its designee. Rather, it is the 

intent of this language to create a procedure for the OCNMS Superintendent to be assured that at 

least one person or entity among the co-applicants, or the applicant itself, has been formally 

designated by the tribe to apply for the permit as a means to advance the interests of the tribe. 

Certification from the governing body of the tribe that the person or entity, whether an applicant 

or co-applicant, has been formally designated by the tribe to apply for the permit could be 

provided in various forms, the most obvious of which is a resolution adopted by the governing 

body of the tribe. There may be other forms of providing the official position of the tribal 

government depending upon the procedures and processes of each tribe. 

Modifications to the tribal welfare permit are expected to have a negligible effect on OCNMS‟ 

physical setting. The modifications being made were developed through consultation with the 

Olympic Coast Intergovernmental Policy Council and the Coastal Treaty Tribes. The goal of the 

modifications is to clarify the role of the tribal welfare permit, more properly referred to as the 

“tribal self-determination permit”, and the circumstances under which it can be issued. These 

clarifications ensure that these permits will only be issued under appropriate circumstances and 

also ensure that inappropriate uses of the permit are avoided (e.g., cases wherein an organization 

not affiliated or working with a tribe attempts to obtain a tribal welfare permit by claiming some 

benefit to a tribe). By modifying the tribal welfare permit language, ONMS is clarifying the 

intent of its regulations to ensure it is used to promote or enhance tribal self-determination and 

not to be used by outside parties. Because this regulatory change does not alter the availability 

of this permit category to American Indian tribes adjacent to the sanctuary, nor change the 

requirement that the permitted activity will not substantially injure Sanctuary resources and 

qualities, this modification to the permitting regulations is expected to have a negligible effect on 

the physical setting. 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

Alternatives B and C also contain some structural changes to the management plan not included 

in alternative A. Under alternatives B and C, the management plan would contain performance 

measures, cost estimates and an implementation table. Alternatives B and C would also include 

a revised suite of goals and objectives for OCNMS. While these structural modifications do 

provide additional clarity and detail to the alternatives, they would have a negligible effect on 

physical resources in the sanctuary.

8.1.2 Actions with Beneficial Effects to the Physical Setting

There are several actions occurring under one or more of the alternatives expected to have a 

beneficial effect on physical resources within the sanctuary. These actions include:

 Routine activities conducted as part of OCNMS‟ resource protection, research, visitor 

services, outreach, education and administrative program areas (alternatives A, B and C)

 A regulatory ban on discharges from cruise ships (alternatives B and C)

 A regulatory ban on discharges from large vessels (alternative C)

 Evaluate (and possibly implement) options to make compliance with the Area-to-beAvoided mandatory (alternative C)

 A regulatory ban on the discharge of invasive species (alternative C)

8.1.2.1 Routine Activities – Effects to the Physical Setting

Many of the routine and general education, outreach, research, resource protection, 

administrative, and visitor services actions taking place under all three alternatives would have 

an indirect, short-term, and less than significant, beneficial effect on physical resources within 

the sanctuary. These routine actions involve the continuation of OCNMS‟ primary program 

areas, including:

 Routine resource protection activities (e.g., marine debris removal)

 Routine research activities (e.g., water quality monitoring)

 Operating sonar for hydrographic surveying

 Routine outreach activities (e.g., citizen science programs)

 Routine education activities (e.g., phytoplankton identification classes)

 Routine visitor services activities (e.g., operating Olympic Coast Discovery Center)

 Routine administrative activities (e.g., enforcement of regulations and permitting)

These routine activities are described in greater detail in the 20 action plans presented in 

section 5. All of these program areas have less than significant, indirect, and beneficial effects 

on physical resources because they promote ocean literacy, improved understanding and 

protection of resources, and improved ocean stewardship. By expanding our knowledge base 

and promoting ocean stewardship principles with partners, local communities and the general 

public, ONMS has the opportunity to influence the behavior and decision-making of individuals, 

communities, organizations and agencies in ways that could indirectly benefit physical resources. 

For example, if a citizen visits an OCNMS fair booth and learns about the importance of marine 

debris removal, s/he may be more likely to participate in a beach clean-up activity. In turn, 

increased participation in beach clean-ups could result in less trash on the beach. 
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While all of these routine actions are beneficial, it is not expected their effects would be 

significant because the anticipated intensity of effects associated with these actions is low. Thus, 

it is not likely a significant improvement in physical resources could be achieved as a result of 

these types of indirect beneficial actions over the five to ten year implementation period for the 

management plan. 

8.1.2.2 Cruise Ship Wastewater Discharges – Effects to the Physical Setting

Under alternative A, no regulatory modifications are proposed and no additional beneficial effect 

to the physical setting would be expected. Alternative B proposes a regulatory ban on all 

discharges within OCNMS from cruise ships (except clean vessel deck wash down, clean vessel 

engine cooling water, clean vessel generator cooling water, clean bilge water or anchor wash) 

that would have a direct, long-term, beneficial, less-than-significant impact on physical resources

(i.e., water quality) because it would prohibit potentially harmful discharges by introduction of 

pollutants, such as bacteria, viruses, solids, pharmaceuticals, organics, nutrients, and metals. 

This regulatory change is discussed in the Water Quality Action Plan in section 5.2. For the 

purpose of this regulation and consistency with regulations for other West Coast national marine 

sanctuaries, cruise ships are considered to be vessels with 250 or more passenger berths for hire.

Cruise ships generate a variety of wastewater discharges on the scale of a small municipality 

with potential , particularly if discharged without treatment, to harm the marine environment. 

The discharges of highest concern in OCNMS based on volume and potential contaminant 

loading are sewage, graywater, and bilge water. Sewage discharges from ships, particularly 

those not using Advanced Water Treatment Systems (AWTS), contain nutrients that create 

biological and chemical oxygen demand and could contribute to algae blooms that, in turn, could 

intensify low dissolved oxygen levels known to occur in the sanctuary. Pathogens from sewage 

have the potential to contaminate commercial or recreational shellfish beds (a human health risk) 

and to harm wildlife and humans directly.

Properly functioning marine sanitation devices (MSDs; described in section 6.1.3 and Appendix 

K) decrease nutrient concentrations in sewage through chemical or biological or other treatment 

technologies. Current federal regulations require all cruise ships treat sewage wastes using a 

Type II MSD. An initial study conducted in 2000 in Alaska of cruise ship waste water 

discharges showed high rates of failure in the ability of conventional MSDs to meet legal 

discharge standards (EPA 2008a). Most cruise ships that transit through OCNMS operate in 

Alaskan waters. Since this study, significant improvements in treatment and monitoring have 

been implemented in some vessels supporting Alaska-Washington routes. AWTS have been 

installed on about 60% of cruise ships transiting through OCNMS. Routine monitoring of these 

systems has been implemented on vessels discharging to Alaska waters, and these systems have 

generally performed well at treating effluent monitored by Alaska Department of Environmental 

Conservation and the US Coast Guard since 2001 (ADEC 2010a). Monitored parameters include 

fecal coliform bacteria (an indicator of potential pathogens), pH, chlorine, biological oxygen 

demand, total suspended solids and other chemical constituents. In 2009, exceedance of 

discharge standards applied to cruise ships occurred most commonly with ammonia, less 

frequently for nickel, copper and zinc, and rarely or never for other tested contaminants (ADEC 

2010a). However, some of the installed AWTS have experienced equipment and operating 

challenges, and are not being used; traditional (Type II) MSDs are used instead. For vessels 

approved to discharge in Washington State waters per the NWCCA MOU, they have the ability 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

and procedures to automatically shut down if continuous monitoring of treated effluent indicates 

high turbidity or a disinfection system upset. When upsets or failures happen, there is a short lag 

time between when the upset occurs, the system acknowledges it and the discharge is stopped, 

which allows a period when ineffectively treated effluents are discharged (Amy Jankowaic, 

WDE, personal communication). 

In general, the dynamic physical, chemical and biological interactions that occur within marine 

ecosystems are not precisely understood, which makes it difficult to determine the amount of 

contaminant loading a system can tolerate, under differing naturally variable conditions, without 

upsetting what may be a delicate natural balance supporting a “healthy” ecosystem. Naturally 

low availability of nutrients in summer months may limit primary productivity in areas off the 

Washington coast (Partridge 2007), and significant nutrient inputs, such as nitrogen in ammonia, 

during summer months could have ecosystem-level effects through alteration of natural primary 

production cycles. In northern waters of the sanctuary, the Juan de Fuca Eddy is an area of high 

primary productivity, as well as an initiating location for harmful algal blooms impacting the 

Washington coast. This eddy lies off the western entrance to the Strait of Juan de Fuca where 

large vessel traffic is most concentrated due to the ATBA and vessel traffic lanes (Figures 8

and 11). The only opportunity for cruise ship discharges into sanctuary waters occurs in this 

area, and vessels could focus discharge in this portion of the sanctuary immediately before 

entering Washington state waters where discharges are limited by the VGP and NWCCA MOU. 

Even with rapid dilution that occurs while vessels are in transit, increased supply of nutrients to 

the Juan de Fuca Eddy area, with its retentive circulation pattern, could stimulate plankton 

growth and enhance initiation of harmful algal bloom events. Moreover, transfer of organic 

materials generated via algal blooms toward the seafloor and subsequent decay can lead to 

depletion of dissolved oxygen (DO) in deep waters creating hypoxic (low DO) conditions, which

can stress or kill organisms such as invertebrates and fish. Because cruise ship traffic through 

the sanctuary is highest in summer months when initiation of harmful algal blooms and low 

oxygen conditions are most prevalent, there is cause for concern about intensification of these 

phenomena given the volume of nutrient rich wastewaters potentially discharged by cruise ships.

Another water quality concern is discharges from properly functioning MSDs also can contain 

high concentrations of formaldehyde or chlorine (which are typically used as sterilizing agents) 

and other chemicals from ship activities, including cleaning chemicals. Although they serve to 

reduce the pathogenicity of discharges, these chemicals themselves pose a threat to water quality 

(NOAA 2008). Other than chlorine, there is limited analytical data on such chemical parameters in 

effluents. Given these complexities, it is difficult to determine the degree to which wastewater 

discharges from cruise ships are or have potential to be compromising water quality of the 

sanctuary.

Graywater discharges, including water from galley, laundry and baths or showers, also have 

potential to degrade water quality. EPA (2008a) evaluated graywater discharges from various 

sources on cruise ships and compared the concentrations of a wide range of constituents to 

untreated domestic wastewater or sewage. Most graywater discharges from cruise ships had 

constituent levels in a similar range to untreated domestic waste water, yet levels for nutrients, 

biological oxygen demand, and fecal coliforms were many times higher than typical domestic 

graywater. Nutrients in graywater could negatively impact water quality in the same manner and 

in combination with discharges of treated sewage from cruise ships. At least 3 of the cruise ships 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

that transit the sanctuary have no graywater treatment system, and they constitute over 30% of 

transits in 2010 and 25% of the transits scheduled for 2011 (WDE 2011) 

Discharge of bilge water from cruise ships has the potential to introduce oils, detergents, 

degreasers, solvents and other harmful chemicals into the marine environment that can harm 

water quality and generate oxygen demand.

Analysis of time in OCNMS and wastewater generation rates indicates a worst-case potential for 

an estimated 0.2 to 1.3 million gallons of treated sewage and 1.5 to 5.0 million gallons of 

graywater (either untreated or treated) to have been discharged by cruise ships (passenger vessels 

>1,600 GT) into the sanctuary in 2009 (Table 6 and Table 7). As discussed in section 8.4.2.2, 

the volume of wastewater actually discharged from cruise ships in the sanctuary is uncertain. 

Moreover, the nutrient and chemical concentrations in both untreated and treated wastewater 

varies depending on the waste streams and performance of wastewater treatment system used. 

Thus, it is difficult to quantify specific reductions in individual nutrients or chemicals that would 

be achieved under any proposed alternative. While industry representatives have stated cruise 

ships currently avoid all discharges in the sanctuary, this has not been verified. Under alternative 

B, all sewage, graywater, bilge and ballast water discharges would be prohibited from cruise 

ships (except clean vessel deck wash down, clean vessel engine cooling water, clean vessel 

generator cooling water, clean bilge water or anchor wash), and potential water quality impacts 

from these discharges would be eliminated. 

The water quality of the sanctuary is generally considered to be good and influenced primarily 

by natural processes (ONMS 2008). Implementing alternative B would result in less than 

significant improvement of water quality over the next 10 years. Elimination of nutrient 

contributions from cruise ship discharges would ensure water quality conditions are not degraded 

by the inputs of additional nutrients, chemical contaminants, and biological and chemical oxygen 

demand associated with these wastewater discharges. 

As discussed in section 6.1.3.1, ballast water discharges within the OCNMS have the potential 

to introduce potentially harmful invasive species. Although alternative B would ban ballast 

water discharges from cruise ships operating in the sanctuary, this aspect of alternative B could 

have negligible effects on water quality because the U.S. federal, Washington and Canadian 

rules currently prohibit all ballast water discharges in OCNMS except for ballast water that 

was exchanged more than 50 nmi from shore. Open ocean ballast water provides a 

significantly reduced risk of introduced species. 

Discharge of any bilge water other than clean bilge water from cruise ships would also be 

prohibited under alternative B. Untreated bilge water discharges can harm water quality and 

the marine environment through the introduction of oils, solvents, and other harmful chemicals, 

with oils being the contaminant of most consistent concern. Because OCNMS regulations 

currently ban oily bilge water discharges, limiting bilge water discharges from cruise ships to 

clean bilge water (i.e., treated bilge water that does not leave a visible sheen) would have little 

to no impact because the standing and final regulations are consistent. 
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8.1.2.3 Wastewater Discharges from Vessels over 300 Gross Tons – Effects to the Physical 

Setting

Under alternative C, wastewater discharges from large vessels over 300 gross tons (GT) would 

be banned (except clean vessel engine cooling water, clean vessel generator cooling water, 

clean bilge water, anchor wash), in addition to prohibitions on discharges from cruise ships

proposed in alternative B. Thus, alternative C encompasses a greater range of vessel classes 

but does not regulate any additional types of discharges beyond those covered in alternative B. 

OCNMS regulations under both alternatives B and C would eliminate discharge of all ballast 

water in OCNMS from cruise ships and large vessels even if an open ocean exchange had 

occurred. These regulations also might alter the quality of bilge water discharged in the 

OCNMS as existing OCNMS regulations allow discharge of bilge water that does not include 

“oily waste”, and new regulations would allow discharge only of “clean bilge water”, which is 

interpreted to mean treated bilgewater that does not leave a visible sheen and can be considered 

more restrictive than the existing OCNMS regulatory language.

It is estimated the more inclusive discharge ban proposed under alternative C could result in a 

potential reduction of sewage discharges of roughly 74%, a 11% reduction (by volume) over 

alternative B (Table 14). Under Alternative C, graywater discharges could potentially be 

reduced by 88%, a 13% reduction over alternative B (Table 14). The same beneficial effects 

expected by implementing alternative B (discussed above) would be realized under alternative 

C. Due to reduced volumes of discharge in the sanctuary, the magnitude of the positive effects 

could potentially be greater under alternative C than under alternative B. However, alternative 

C is still expected to have less than significant effects on the overall water quality of OCNMS 

because the sanctuary‟s water quality is already considered good and, given the sanctuary‟s 

large size, the discharge reduction achieved under alternative C would not likely result in a 

substantial improvement of water quality (i.e., from „good‟ to „excellent‟).

8.1.2.4 Area-to-be-Avoided – Effects to the Physical Setting

Currently, the Olympic Coast Area to be Avoided (ATBA) is an International Maritime 

Organization (IMO) voluntary vessel routing measure for vessels 1,600 gross tons and above. 

The ATBA has been in place since 1994, and its compliance rate has been high, estimated to be 

98.9% in 2009 (WDE 2010). To maintain the high compliance rate, ONMS works with the 

USCG to notify non-compliant vessels, then send a formal letter requesting vessel owners or 

operators to adhere to the ATBA in the future. 

Under alternatives A and B, the ATBA would remain voluntary and continue to apply to all ships 

and barges carrying cargoes of oil or hazardous materials and all ships 1,600 gross tons and 

above solely in transit. It would also apply to additional classes of vessels based on recent 

legislation. The Coast Guard Authorization Act for Fiscal Years 2010 and 2011 calls on NOAA 

to work with the USCG to revise the ATBA so existing restrictions apply to additional vessels. 

This change would apply to vessels between 400 GT and 1,600 GT, other than fishing or 

research vessels while engaged in fishing or research within the ATBA.
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Table 14 Comparison of estimated potential discharges (in gallons) under alternatives A, B and C

Vessel Classification

Alternative A Alternative B Alternative C

Sewage 

Discharge 

Volume (avg)

Graywater 

Discharge 

Volume (avg)

Sewage 

Discharge 

Volume (avg)

Graywater 

Discharge

Volume (avg)

Sewage 

Discharge 

Volume (avg)

Graywater 

Discharge 

Volume (avg)

Commercial Fishing Vessel 94,620 422,636 94,620 422,636 94,620* 422,636 * 

Charter Fishing Vessel 45,633 not estimated 45,633 not estimated 45,633 not estimated 

Recreational Fishing Vessel 108,686 not estimated 108,686 not estimated 108,686 not estimated 

Commercial Vessel < 300GT 2,052 9,166 2,052 9,166 2,052 9,166 

Commercial Vessel 300-1599 GT 1,782 7,960 1,782 7,960 prohibited prohibited 

Commercial Vessel > 1600 GT 63,045 281,601 63,045 281,601 prohibited prohibited 

Passenger Vessel < 300 GT 3,600 16,080 prohibited prohibited 3,600 16,080

Passenger Vessel 300-1599 GT 6,000 26,800 prohibited prohibited prohibited prohibited 

Passenger Vessel > 1600 GT 630,936 2,818,181 prohibited prohibited prohibited prohibited 

Public Vessel < 300 GT 63 281 63 281 63 281 

Public Vessel 300-1599 GT 1,248 5,574 1,248 5,574 prohibited prohibited 

Public Vessel > 1600 GT 3,893 17,387 3,893 17,387 prohibited prohibited 

Tank Vessel 32,715 146,127 32,715 146,127 prohibited prohibited 

Tug with tank barge 2,124 9,487 2,124 9,487 2,124 9,487 

TOTAL DISCHARGE 996,396 3,761,280 365,460 943,099 256,778 457,650

DECREASE from Status Quo – – 630,936 2,818,181 739,619 3,303,629

Percent reduction in potential 

discharge from Status Quo 0% 0% 63% 75% 74% 88%

* A number of Commercial Fishing Vessels transiting the sanctuary are > 300 GT and would also be affected by Alternative C. These are not included because the data used in 

the analysis does not provide tonnage.
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Thus, under alternatives A and B, the ATBA is expected to continue to have a less than 

significant, beneficial, indirect, long-term effect on physical resources by keeping ships posing a 

spill risk (i.e., potentially large-scale shoreline impacts of a fuel or materials spill) further 

offshore. The effect is considered less than significant because, while it reduces the risk of a 

spill occurring in the sanctuary and increases the response time between a spill and when oil 

would impact the shore, the ATBA does not directly prevent spills from occurring. Another 

impact of vessel traffic on the physical environment, underwater noise, also is not addressed 

under alternatives A and B. Effects of vessel noise (and effects of noise pollution, in general) are 

discussed in section 8.5, Cumulative Effects.

Under alternative C, ONMS would work with its partners to evaluate options to make 

compliance with the ATBA mandatory. Mandatory ATBA compliance could have an additional 

beneficial effect (beyond alternatives A and B) on physical resources.

In order to understand the extent and potential significance of this beneficial effect, ONMS 

evaluated ATBA compliance rates and identified the population of vessels not voluntarily 

complying with the ATBA. ONMS further evaluated responses from the ATBA Monitoring and 

Outreach program to evaluate response from the industry on reasons for non-compliance.

The transits of vessels for which the ATBA applied off the Olympic Coast in 2009 are 

summarized in Table 15. In 2009, 8,849 transits (vessels for which the ATBA applies) were 

tracked by CVTS monitoring, which extends south to approximately 48 degrees North. Of these 

transits, 6,128 entered OCNMS (Figure 11), with a total of 68 transiting within the ATBA

(Figure 12). In 2009 the ATBA voluntary compliance rate was estimated at near 99%.

In 2009, there were a total of 68 non-compliant transits, representing 59 different vessels, 

through OCNMS (Figure 12). This is the population of vessels to which the potential mandatory 

ATBA provisions would have applied if in effect in 2009. The change from voluntary to 

mandatory would only increase resource protection to the sanctuary if it results in increased 

compliance to the ATBA provisions. In 2009, 37 letters were sent to non-compliant vessels, this 

accounted for 54% of the 68 non-compliant vessels. In some instances tracking data may show a 

vessel just inside the boundaries of the ATBA, in some of these cases letters are not sent. Of 

letters sent out in 2009, ONMS received 14 replies from vessel owners or agents. In all but a 

single case, the responses acknowledged the ATBA incursion, and replied that they had taken 

action to educate their vessel(s) and committed to future compliance. In the single case where 

the vessel‟s master did not agree with the determination that their vessel was in the ATBA, they 

responded they approached, but did not enter the ATBA. A review of the vessel track shows the 

vessel entered, but only for a very short period of time. Even in this instance the vessel owners 

agreed to take action to ensure all the vessels in their fleet would avoid the ATBA in the future. 

ONMS has concluded changing the ATBA provisions from voluntary to mandatory would have 

negligible effects on physical resources in the sanctuary, based on the level of observed 

cooperation by the maritime community and the lack of documented cases where mariners have 

elected to ignore the voluntary nature of the ATBA. In addition, modification of the ATBA 

would require submitting a U.S. government proposal to the Marine Safety Committee of the 

IMO. When considering vessel routing measures used for the purposes of environmental 

protection, the IMO balances the need for natural resource protection with the protection of 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

traditional freedoms of navigation. Given the current high rate of compliance, NOAA does not 

believe a request to change the ATBA from voluntary to mandatory would be favorably 

received. For these reasons, changing the voluntary nature of the ATBA is not included in 

OCNMS‟ preferred alternative. 

Table 15 All Cooperative Vessel Traffic Service (CVTS) vessel transits in 2009

Vessel Type

Transits in and out of 

the Strait of Juan de 

Fuca recorded by the 

CVTS1

Transits 

passing 

through the 

Sanctuary2

Transits passing 

through the 

ATBA within the 

Sanctuary3

Estimated 

ATBA 

Compliance 

Rate4

Articulated Tank Barges 265 257 1 99.6%

Bulk Carriers 2747 1776 19 98.9%

Cable Layers 23 10 0 100.0%

Chemical Tankers 325 240 1 99.6%

Container Ships 2412 1575 15 99.0%

Cruise Ships 450 280 2 99.3%

Fishing Vessels (in transit) 111 81 4 95.0%

General Cargo Ships 487 366 5 98.6%

Heavy Load Carriers 15 14 1 92.9%

Hopper Dredger 2 2 0 100.0%

Liquefied Petroleum Gas Carriers 

(LPG) and Liquefied Natural Gas 

(LNG) Carriers

6 3 0 100.0%

Non-oil Tankers 73 57 1 98.2%

Oil Tankers 1056 838 7 99.2%

Ore-Bulk-Oil Vessels (OBO) 12 7 0 100.0%

Refrigerated Ships 6 4 0 100.0%

Roll-on Roll-off Vessels (RORO) 353 201 2 99.0%

Vehicle Carriers 402 323 1 99.7%

Tugs with Chemical Barges 3 3 1 66.7%

Tugs with Oil Barges 101 91 8 91.2%

8849 6128 68 98.9%

 

1 The vessel transits in this column were provided by the CVTS and include commercial vessels greater than 1600 

gross tons, or tugs with laden oil or chemical barges.

2 This column includes a subset of the CVTS vessel transits through the sanctuary.

3 This column includes a subset of the sanctuary vessel transits that also go through the ATBA. These are vessels 

potentially not complying with the provisions of the ATBA. These are identified both by CVTS radar and by Seattle 

Marine Exchange AIS.

4 This column shows the percentage of vessels transiting through the Sanctuary that stayed out of the ATBA

{Column 4 = 1 – (Column3/Column2)}. This is used as an estimate of compliance with ATBA provisions.
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

Figure 11 CVTS radar coverage – OCNMS 2009 transit track lines (6,128 transits)
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

Figure 12 CVTS radar coverage – ATBA 2009 transit track lines (68 transits)
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

8.1.2.5 Invasive Species Discharge Regulation – Effects to the Physical Setting

Under alternative C, ONMS would establish a new regulation banning the discharge of invasive 

species in the sanctuary, in addition to conducting a series of non-regulatory actions to address 

invasive species. Under alternatives A and B, this regulation would not be pursued, and invasive 

species would be addressed solely through non-regulatory actions (e.g., monitoring).

Banning the direct discharge or release of invasive species in the sanctuary would have a 

beneficial, long-term effect on physical resources in the sanctuary. 

Invasive species can affect physical resources in several ways. Some invasive species, such as 

certain invasive tunicates, are sedentary for at least part of their lives and affix to substrates, thus 

altering the physical environment. Invasive species also can also affect water quality (e.g., by 

altering nutrient levels or turbidity). By prohibiting the discharge of invasive species in the 

sanctuary, ONMS would be complementing and expanding the area addressed by state of 

Washington regulations developed to prevent the introduction of invasive species into state 

waters. In most cases, the effects of this new regulation on physical resources would be indirect 

because the regulation would prohibit discharge of organisms, effects of which would likely 

occur at locations and times removed from the initial introduction of the organism. 

The beneficial effect of this action on physical resources is assumed to be less than significant 

because the state of Washington already implements ballast water regulations that reduce the risk 

of invasive species introductions within the sanctuary. Ballast water is a primary invasive 

species transport vector in marine environments. Over 80 percent of the world's commodities are 

transported via ships, and these ships results in an annual transfer of an estimated 10 to 12 billion 

tons of ballast water across the globe (Global Ballast Water Programme 2003). The World

Resources Institute estimates 3,000 aquatic species are transported around the globe every day in 

the ballast water of ships (IMO 2010). 

The current Washington state regulations require vessels travelling to Washington from outside 

of the United States exchange their ballast water at a distance greater than 200 nmi from shore 

and in waters greater than 2000 meters. Vessels traveling between U.S. ports on the West Coast 

must exchange ballast water at a distance greater than 50 nmi from shore and in waters at least 

200 meters deep. Because the sanctuary, at its widest, extends 40 nmi from shore, no ballast 

water exchanges should be occurring in the sanctuary. 

Thus, it is assumed an OCNMS invasive species discharge ban would have an added beneficial 

effect primarily on invasive species introductions occurring through vectors other than ballast 

water. These vectors could include people disposing of exotic aquarium fish or carrying an 

invasive species on their boats. Current Washington state regulations prohibit release of any 

classified aquatic nuisance species (lists were developed for the state‟s administrative code) or 

any unclassified aquatic species with potential to be a nuisance species. These types of 

introductions often occur unintentionally and due to a lack of understanding and awareness of 

invasive species concerns. Thus, an OCNMS regulation prohibiting invasive species 

introductions alone would complement state regulations but likely not have a significant 

beneficial effect. It is likely the routine, non-regulatory resource protection activities occurring

under all three alternatives and would be focused on invasive species monitoring, education and 

outreach would be as effective in preventing these types of invasive species introductions (e.g., 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

by educating people about the threats posed by invasive species) than would an invasive species 

regulation.

8.1.3 Actions with Adverse Effects to the Physical Setting

One regulatory change proposed under alternative C could have an adverse effect to the physical 

setting - reducing the OCNMS overflight regulation from 2,000 feet to 1,000 feet. 

Several non-regulatory actions being considered under alternatives A, B and C would result in 

some adverse effects to physical resources in the sanctuary. Alternative A (i.e., continued 

management using the 1994 OCNMS management plan) does not define many of these actions 

with the level of detail provided in alternatives B and C. However, because the original 1994 

OCNMS management plan is so broad and general in nature, this analysis assumes any adverse 

effects associated with these activities would occur under alternative A.

8.1.3.1 Overflight Floor Reduction – Effects to the Physical Setting

A lowering of the overflight floor would not likely alter the number or type of planes flying over 

the sanctuary, but this regulatory change could affect the physical setting of the sanctuary by 

increasing the noise detectable and visual impact to visitors to the shoreline adjacent to the 

sanctuary, much of which is designated wilderness within Olympic National Park. Federal 

wilderness lands are characterized as areas of undeveloped land retaining its primeval character 

and influence, without permanent improvements or human habitation, which is protected and 

managed to preserve its natural conditions, and where the imprint of man‟s work is substantially 

unnoticeable and there are outstanding opportunities for solitude. The 2,000 foot FAA advisory 

that applies to national parks and wildlife refuges mitigates the visual and acoustic impact to 

wildlife as well as visitors. Based on its effect to the aesthetic value of the ONP wilderness 

shoreline, this alternative would have an adverse, direct, and long-term effect on physical 

resources.

8.1.3.2 Seabed Disturbance from Research Activities – Effects to the Physical Setting

Alternatives A, B and C consider research, monitoring and assessment actions related to habitat 

mapping, and water quality and oceanographic monitoring that may necessitate disturbance of 

the seafloor in the sanctuary. Seafloor disturbance typically would occur when:

 Anchoring water quality and oceanographic monitoring buoys

 Collecting benthic sediment samples to support habitat mapping and characterization 

efforts and to identify infaunal communities

In regards to anchoring monitoring buoys, in recent years there have been 13 buoys seasonally 

deployed by ONMS in the sanctuary. These OCNMS buoys are conducted under the OCNMS 

Superintendent‟s Permit that covers activities by OCNMS directly related to management of the 

sanctuary. Like other permitted activities within the sanctuary, activities conducted under the 

Superintendent‟s Permit must not substantially injure sanctuary resources and qualities. There are 

additional research buoys permitted and installed by other entities in the sanctuary, but the 

environmental effects of these buoys are evaluated when permit applications to install them are 

evaluated. The effects of these non-OCNMS buoys are therefore only considered within the 

context of cumulative effects (section 8.5). 
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OCNMS buoys are anchored with two steel blocks (120 pounds each; approximately 30cm x 

30cm x 10cm) sitting on less than 0.5 m2of seafloor and approximately 2m of iron chain linked 

to ropes and floats. The adverse effect caused by these weights and chain is direct but less than 

significant because the anchors are relatively small in size and few in number, so they impact a 

miniscule percentage of sanctuary seafloor; anchors are deployed on soft rather than rocky 

seafloor (soft seafloor habitats are more disturbance tolerant and recover more quickly than hard 

seafloor habitats); moorings have a subsurface float designed to keep chain orientation vertical 

and off the seafloor; and weights generally remain in place without dragging. The effects are

short-term because the anchors are retrieved, and it is expected the habitats where the anchors sit

recover relatively quickly (within a year) following this physical disturbance. If the connection 

to the mooring floats is broken, there is a risk weights could be abandoned, which would cause

localized but longer-term effects where the weights sit on the seafloor. This occurs infrequently,

and the steel used in the anchors is not acutely toxic to biota. 

For habitat characterization work, benthic sediment sampling is performed for each unique 

benthic habitat type to verify, or ground-truth, and refine interpretations of remotely-collected 

data. Benthic sediment samples are collected using grab samplers with a footprint impacting less 

than 0.5 m2of seabed and a physical sample removed from an area 0.1m2or less. Samples are 

collected at intervals of approximately 2000 meters until that sediment type can be reliably 

identified with remotely-collected data. In addition, benthic samples from sedimentary areas 

occasionally are collected from subtidal areas to identify the community of animals living in the 

sediments. Sampling may affect the seafloor by physical removal of samples (sediment grabs or 

ROV sampling) or inadvertent contact with the seafloor (video sleds or ROV/AUV equipment). 

The adverse effects to the seafloor from benthic sediment sampling are expected to be direct and 

less than significant because the sampling devices impact a small area of the seafloor (generally 

0.5m

2

or less) in areas of sedimentation (not hard substrate), disturbance is limited to the upper 

few centimeters of sediment, and sampling is done at wide spatial and temporal intervals, 

therefore, the intensity of effect is low. The effects of this sediment sampling are short-term 

given the area impacted and substrates targeted. If seafloor sampling activities inadvertently

impacts hard substrate, long-term effects may result if coral/sponge habitat is damaged because 

this biogenic habitat recovers slowly. However, this is not a planned activity, the damage is not 

anticipated, and the extent is expected to be de minimis. 

Currently, approximately 25% of the OCNMS seafloor has been mapped and characterized. 

Under alternatives A, B and C habitat mapping and characterization efforts as well as benthic 

research would continue and efforts may increase (dependent upon resources). Therefore, 

additional localized, short-term effects to physical resources would be anticipated; however, the 

intensity of the effects is low as described above. To the extent that the level of effort increases, 

there is potential for additional adverse effects to physical resources; however, these are less than 

significant. 

8.1.3.3 Operating Vessels in Sanctuary – Effects to the Physical Setting

Several actions being considered under alternatives A, B and C involve the operation of vessels 

in the sanctuary, which has the potential to cause adverse effects to physical resources. Actions 

involving the operation of OCNMS vessels (or vessels operating on behalf of OCNMS) include:
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 On-water enforcement activities

 Research, monitoring and assessment activities

 Outreach and education activities

OCNMS staff operates a 38‟, diesel powered research vessel and a rigid-hull inflatable boat. 

OCNMS research and monitoring projects also involve the use of other NOAA or contracted 

vessels. OCNMS‟ RV Tatoosh (Figure 13) is occasionally used (no more than five times per 

year) for training, outreach and education activities (e.g., trips in the sanctuary for OCNMS 

volunteers). Additionally, the OCNMS vessels are occasionally used to investigate potential 

regulatory violations (less than five times per year, on average).

Figure 13 OCNMS Research Vessel Tatoosh

During a typical calendar year, OCNMS research vessels are operating in the sanctuary about

300 hours total. The exact number of hours varies from year to year based upon funding and 

operational and vessel repair needs. In some years, non-OCNMS vessels operate in the 

sanctuary on behalf of OCNMS in order to conduct research or enforcement activities but the 

number of hours varies considerably from year to year. Vessel operations contribute to 

temporary, localized noise and air pollution in the sanctuary, may collide with marine life, and 

pose a risk of hazardous materials spills or of sinking. 
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The effects of operating OCNMS research vessels in the sanctuary are direct, adverse and less 

than significant. Vessels are maintained and operated according to rigorous NOAA safety 

guidelines, have a good safety record, and carry relatively small amounts of hazardous materials. 

Thus, the risk of a hazardous materials spill or vessel sinking is low. ONMS ensures any 

research or enforcement vessels operating in the sanctuary on its behalf are maintained and 

operated by qualified organizations (often other government agencies). 

Because OCNMS vessels and those acting on behalf of ONMS operate in the sanctuary an 

average of a few hundred hours per year, their presence is temporary and use is distributed over a 

large area, it is expected the effects of noise and air pollution from these activities is less than 

significant. Noise pollution and the presence of a vessel can alter the physical environment of 

the sanctuary and cause both direct effects (e.g., distract an organism from its current path) and 

indirect effects (e.g., alter travel paths in a way that steers organisms away from necessary food 

sources) to biological resources (discussed in section 8.2). If noise from human activities is 

elevated to levels considered “pollution” or chronic disturbance, it is more likely to result from 

the cumulative effect of all the vessels operating in the sanctuary, including the numerous vessels 

not operating on behalf of OCNMS. The cumulative effects of noise pollution are discussed in 

section 8.5. 

8.1.3.4 Conducting Activities in Intertidal Areas – Effects to the Physical Setting

Alternatives A, B and C also consider actions potentially causing adverse effects to shore and 

intertidal physical resources. These actions include:

 Beach and intertidal educational and interpretive programs

 Intertidal monitoring surveys

 Marine debris removal projects

 Encouraging visitation to beaches and intertidal areas

OCNMS actions in the intertidal zone are expected to have direct, but less than significant,

adverse effects on physical resources. Interpretive efforts that encourage visitation to beaches 

and intertidal zones can cause trampling. Intertidal educational and interpretive programs 

typically involve small groups traversing intertidal habitat and can trample invertebrates and 

algae on rocky surfaces. In intertidal habitats, biological organisms are considered elements of 

the physical habitat. OCNMS-led intertidal survey teams also can cause trampling damage. 

Marine debris removal on beaches sponsored by OCNMS and its partners can cause trampling 

disturbance of intertidal habitats and also result in debris being dragged along the shore, thus 

causing physical disturbance. 

These adverse effects are less than significant because the habitat disturbance occurring is widely 

distributed in space and time, and generally caused by small groups of people. Therefore, the 

effects are low intensity and short-term. Moreover, participants in OCNMS stewardship, 

interpretive, educational and research programs typically are instructed on proper beach etiquette 

and ways to minimize their impacts on intertidal habitats. The purpose of these actions is to 

improve ocean literacy, educate people on becoming better stewards of ocean ecosystems, reduce 

the impacts of marine debris, and improve our understanding of intertidal community ecology –

all of which are outcomes beneficially influencing long-term efforts to protect these resources. 
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The overwhelmingly beneficial effects of these activities outweigh the less than significant,

adverse effects that may occur.

8.1.4 Summary of Effects to Physical Setting

In general, the majority of actions being considered under alternatives A, B and C would have a 

primarily beneficial, less than significant effect on physical resources in the sanctuary. This is 

because many of the actions, while important to achieving OCNMS‟ goals and objectives, are 

relatively small in scale and are not expected to cause a significant improvement to physical 

resources over the life of the management plan (five to ten years). There is not a significant 

difference between the beneficial effects to physical resources of the three alternatives. 

Alternative C would have a greater overall beneficial effect on physical resources, due to the 

several additional actions it considers; but, as discussed above, this effect would not be 

significant. 

Water quality in the sanctuary, according to the 2008 OCNMS Condition Report, is “good”. It is 

unlikely the proposed reductions in discharges would cause a substantial improvement in water 

quality over the next 10 years. However, reducing wastewater discharges would reduce the risk 

of water quality impacts associated with wastewater discharges and could alleviate stress on 

sanctuary ecosystems. Thus, reducing wastewater discharge in the sanctuary could have a less 

than significant, beneficial effect by helping maintain the high water quality in the sanctuary into 

the future. 

Regarding adverse effects to physical resources, several are associated with the actions being 

considered under the three alternatives, but none of these adverse effects would be significant. 

There is not a significant difference between the adverse effects to physical resources of the three 

alternatives. 
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8.2 BIOLOGICAL SETTING

8.2.1 Actions with Negligible Effect to Biological Setting

There are several actions occurring under all three alternatives that are expected to have a 

negligible effect on biological resources within the sanctuary. These actions include:

 Structural changes to the format of the OCNMS management plan, and revisions to the 

OCNMS goals and objectives

 Routine office and classroom activities, including meetings, visitor, education and 

training programs that take place in existing OCNMS or other facilities

 Use of Information Technology resources, including internet technology, data 

management programs, phone and e-mail technology

 Routine outreach activities not occurring in the sanctuary, including staffing fair booths 

and attending community events

 Routine maritime heritage activities

These actions are expected to have a negligible effect on biological resources for various reasons 

– they are administrative in nature, occur within existing facilities, do not involve any direct or 

indirect interaction between the people conducting the actions and biological resources, or no 

construction or physical development is required to conduct these actions. 

There are several actions proposed only under alternatives B and C involving modifications to 

OCNMS regulations with negligible effects on biological resources. These include:

 Technical clarifications to OCNMS regulations as outlined in the Sanctuary Operations 

Action Plan (strategy OPS 9, activity H)

 Replace the term “traditional fishing” with “lawful fishing”

 Modifications to the tribal welfare permit provision in the OCNMS regulations 

 Reducing the OCNMS overflight regulation from 2,000 feet to 1,000 feet (alternative C)

The technical clarifications to OCNMS regulations would not affect the biological resources 

within the sanctuary because the changes are language clarifications that do not alter the meaning 

or intent of the regulations. 

The current OCNMS regulations define the term “traditional fishing” as “using a fishing method 

that has been used in the sanctuary before the effective date of sanctuary designation (July 22, 

1994), including the retrieval of fishing gear” and provide an exception for traditional fishing 

operations to three of the regulatory prohibitions – prohibitions on discharge of certain fishingrelated materials, disturbance to historical resources, and disturbance to the seabed. OCNMS 

regulations could be interpreted to mean that fishing methods or operations that do not fall within 

the definition of “traditional fishing” are not allowed to discharge materials mentioned above, or 

disturb historical resources or the seabed. 

As part of this action, NOAA is replacing the term “traditional fishing” with the term “lawful 

fishing” in these three places to: 1) use a more clearly understood term; and 2) eliminate the 

distinction between fishing methods that were used before OCNMS designation from those that 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

have since been authorized. By replacing the word “traditional” with “lawful” NOAA would 

unambiguously recognize fishing activities authorized by governmental fisheries management 

authorities. This change is expected to have a negligible effect because Federal, state, tribal and 

regional fishery management authorities currently analyze and attempt to mitigate impacts 

associated with lawful fishing, including that which has occurred traditionally in the sanctuary, 

and those authorities are expected to do the same in the future. Since the scope and impacts of 

any such future management actions are speculative at this point, it is not possible, and would be 

inappropriate, to speculate on any additional impact analysis in this document. See section 8.1.1 

for more discussion on the regulatory change to replace the phrase “traditional fishing” with 

“lawful fishing”. 

Under the current regulations, ONMS can issue a permit to conduct an activity otherwise 

prohibited if it finds that the activity will meet criteria identified in the regulations. One of the 

criteria listed for permit issuance is to “promote the welfare of any Indian tribe adjacent to the 

sanctuary.” This provision is ambiguous and could be interpreted as allowing an entity not 

affiliated with a tribe to apply for a permit that it alleges could promote the welfare of an Indian 

tribe adjacent to the sanctuary. By modifying the tribal welfare permit language, ONMS is 

clarifying the intent of its regulations to ensure it is used to promote or enhance tribal selfdetermination and not to be used by outside parties. Because this regulatory change does not 

alter the availability of this permit category to American Indian tribes adjacent to the sanctuary, 

nor change the requirement that the permitted activity will not substantially injure Sanctuary 

resources and qualities, this modification to the permitting regulations is expected to have a 

negligible effect on the biological setting. See section 8.1.1 for more discussion on the 

regulatory change to clarify the permitting language.

A lowering of the overflight floor from 2,000 feet to 1,000 feet would not affect biological 

resources because there is evidence wildlife disturbance from overflights occurs primarily at 

elevations below, but not above, 1,000 feet. Low overflights in OCNMS pose a risk of harmful 

disturbance to marine mammals and seabirds. Examples of harmful disturbance include movement 

and evacuation in response to low overflights where the young (pups, chicks, eggs) are crushed 

during an evacuation or exposed to predation as a consequence of loss of parental protection. 

Studies of overflights have confirmed low altitude overflights do cause wildlife disturbance, but 

effects vary with plane type, elevation, flight pattern and wildlife species (Parrish et al. 2005). For 

example, helicopters tend to cause more disturbance than fixed wing planes; repeated passes cause 

more disturbance than a single pass. Based on observed disturbance caused by overflights, various 

authors have recommended a buffer (or distance aircraft should stay from wildlife) ranging from 

500 to 5,000 feet, depending on the species under consideration (Parrish et al. 2005). Existing 

altitude restrictions from various locations for protection of various species from aircraft 

disturbance range from 500 to 2,000 feet (ONMS 1997). 

Wildlife biologists and pilots who regularly conduct surveys off the coast of Washington 

typically request an OCNMS permit to fly between 600 and 1,000 feet altitude to optimize their 

capabilities for census and behavioral observations. Because the purpose of these flights is to 

observe undisturbed wildlife (seabirds and marine mammals) for census counts, disturbance 

would be counterproductive to their purposes. Their personal observations over several decades 

of work are that wildlife disturbance does not commonly occur with species found off the 

Olympic Coast for flights above 1,000 feet. It is assumed a lowering of the overflight floor 
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to 1,000 feet, as proposed in alternative C, would not increase the number of low altitude 

(<1,000 feet) flights over the sanctuary, and that flights at or above 1,000 feet do not normally 

cause observable disturbance to wildlife. Therefore, modification of the OCNMS overflight 

regulation to 1,000 feet would have negligible effects on biological resources within the 

sanctuary. 

In addition, alternatives B and C also contain some structural changes not included in alternative 

A. Under alternatives B and C, the management plan would contain performance measures, cost 

estimates and an implementation table. Alternatives B and C also would include a revised suite 

of goals and objectives for OCNMS. While these structural changes would have a negligible 

effect on biological resources, these modifications do provide additional clarity and detail to 

alternatives B and C.

8.2.2 Actions with Beneficial Effects to the Biological Setting

There are several actions occurring in one or more of the alternatives expected to have a 

beneficial effect on biological resources within the sanctuary. These actions include:

 Routine activities conducted as part of OCNMS‟ resource protection, research, visitor 

services, outreach, education and administrative program areas

 A regulatory ban on cruise ship discharge (alternatives B and C)

 A regulatory ban on discharges from large vessels (alternative C)

 Evaluate (and possibly implement) options to make compliance with the Area-to-beAvoided mandatory (alternative C)

 A regulatory ban on the discharge of invasive species (alternative C)

8.2.2.1 Routine Activities – Effects to the Biological Setting

Many of the routine and general education, outreach, research, resource protection, 

administrative and visitor services actions would take place under all three alternatives. These 

routine actions (detailed throughout the 20 action plans in section 5) involve the continuation of 

OCNMS‟ primary program areas, including:

 Routine resource protection activities (e.g., marine debris removal)

 Routine research activities (e.g., intertidal and water quality monitoring)

 Routine outreach activities (e.g., citizen science programs)

 Routine education activities (e.g., teacher training classes)

 Routine visitor services activities (e.g., operating the Olympic Coast Discovery Center)

 Routine administrative activities (e.g., enforcement of regulations and permitting)

All of these program areas have less than significant, short-term, indirect, and beneficial effects 

on biological resources because they promote ocean literacy, improved understanding and 

protection of natural resources, and improved ocean stewardship. By promoting these principles 

with partners, local communities and the general public, OCNMS has the opportunity to 

influence the behavior and decision-making of individuals, communities, organizations and 

agencies in ways benefiting biological resources. For example, if a citizen visits an OCNMS fair 

booth and learns about the importance of marine debris removal, he/she may be more likely to 

participate in a beach clean-up activity and less likely to dispose of trash in or near the ocean. In 
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turn, increased participation in beach clean-ups could result, over time, in less trash on the beach, 

which could result in fewer impacts of marine debris to wildlife. 

While all of these routine actions are beneficial, it is not expected their effects would be 

significant. The expected implementation period of the management plan is no more than 10 

years; thus, for the purposes of this analysis, the actions proposed within all three management 

plan alternatives are not projected to last longer than 10 years. It is not likely a significant 

improvement in biological resources could be achieved on such a short timeframe as a result of 

these types of indirect, beneficial actions. 

8.2.2.2 Vessel Discharges – Effects to the Biological Setting

Alternatives B and C both contain modifications to OCNMS vessel discharge regulations. Under 

alternative A, none of these regulatory modifications would be made and thus, no additional 

beneficial effect to the biological setting would be expected. Alternative B proposes a regulatory 

ban on discharges from cruise ships, with specific types of clean discharges allowed. Alternative 

C proposes a ban on discharges from large vessels (over 300 gross tons) along with the same 

cruise ship discharge ban as Alternative B, with specific types of clean discharges allowed. In 

addition, alternatives B and C also contain non-regulatory strategies in the Water Quality 

Protection Action Plan related to reducing impacts from vessel discharges (e.g., work with 

partners to improve availability of sewage pump-out facilities). Section 8.2.1 reviews the 

expected effects of these non-regulatory actions on biological resources. It is presumed these 

non-regulatory activities could take place under alternative A, though alternative A does not 

identify them explicitly. 

By reducing the amount of wastewater being discharged into the sanctuary through regulatory 

modifications, both alternatives B and C would have a beneficial and long-term effect on 

biological resources in the sanctuary. The effect would be long-term because the changes to 

regulations would presumably remain in place for the foreseeable future (i.e., beyond one 

management plan cycle). The reduction in wastewater discharge volumes potentially achieved 

under alternatives B and C is documented in detail in section 8.1.2. It is estimated that 

alternative B potentially could result in wastewater discharge reductions of up to 3.4 million

gallons (sewage and graywater combined) from cruise ships per year (Table 14). Alternative C 

potentially could result in a reduction of up to 4.0 million gallons of wastewater discharged in 

the sanctuary per year (Table 14). It is important to note estimated reductions in discharge 

volumes are based on estimated wastewater generation rates for the known time intervals that 

vessels are in the sanctuary, not on actual practice or knowledge of where wastewaters are 

discharged. 

Sewage and graywater discharges can negatively affect biological resources in a variety of ways. 

Wastewater can contain harmful bacteria, protozoa, and viruses. These pathogens have the 

potential to contaminate commercial or recreational shellfish beds (a human health risk) and to 

harm wildlife and humans directly. Analysis of graywater discharges from cruise ships revealed 

levels of nutrients, biological oxygen demand and fecal coliforms were many times higher than 

typical domestic graywater (EPA 2008a). Nutrients and biological oxygen demand in graywater 

could negatively impact water quality in the same manner and in combination with discharges of 

treated sewage from cruise ships. Fecal coliforms are an indicator of pathogens. In general, 

pathogen concentrations are not currently a concern in the sanctuary (ONMS 2008), yet there are 
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clear indications sea otters have been exposed to pathogens that have compromised the health in 

sea otter populations off California and elsewhere (Brancato et al. 2009). Pathogens can also 

affect human health through consumption of contaminated shellfish. Whereas AWTS may be 

highly effective at reducing bacterial contamination, they may not be as effective in elimination 

of pharmaceuticals and viruses, and fecal coliforms are not a good indicator of wastewater 

treatment effectiveness for viruses (WDH 2007). As a result, Washington Department of Health 

recommended and the NWCCA MOU adopted a provision that no cruise ship discharges will 

occur within 0.5 nmi of harvested shellfish beds. Prohibiting the introduction of pathogens from 

cruise ship and large vessel sewage and graywater discharges in a more comprehensive area 

could help reduce further pathogen exposure and prevent health impacts to humans and wildlife 

in the sanctuary.

Wastewater discharges from vessels can also indirectly affect biological resources. Wastewater 

contains nutrients with potential to stimulate algal blooms, including species harmful to humans. 

Transfer of organic materials generated via algal blooms toward the seafloor and subsequent 

decay can lead to depletion of dissolved oxygen (DO) in deep waters. Hypoxic (low DO) 

conditions can stress or kill organisms such as invertebrates and fish. Naturally low availability 

of nutrients in summer months may limit primary productivity in areas off the Washington coast 

(Partridge 2007), and significant nutrient inputs during summer months could have ecosystemlevel effects through alteration of natural primary production cycles. In northern waters of the 

sanctuary, the Juan de Fuca Eddy is an area of high primary productivity as well as an initiation 

area for harmful algal blooms impacting the Washington coast. This eddy lies off the western 

entrance to the Strait of Juan de Fuca where large vessel traffic is most concentrated due to the 

ATBA and vessel traffic lanes (Figures 8 and 11). The only opportunity for cruise ship 

discharges into sanctuary waters occurs in this area, and vessels could focus discharge in this 

portion of the sanctuary immediately before entering Washington state waters where discharges 

are limited by the VGP and NWCCA MOU. Even with rapid dilution that occurs while vessels 

are in transit, increased supply of nutrients to this area, with its retentive circulation pattern, 

could alter productivity patterns and have ecosystem-level effects on the marine life that benefits 

from this productivity. In addition, an increased occurrence of harmful algal blooms could 

impact wildlife and human populations of the area. 

While there is a risk wastewater discharges could affect the biological setting, it is difficult to 

determine what volume or content of wastewater would trigger effects. No significantly adverse 

effects attributable to wastewater discharge in the sanctuary have been documented, and the 2008 

Condition Report rated water quality in the sanctuary as “good” (ONMS 2008). Because the 

reduction in wastewater discharge that would be achieved under alternatives B and C can be 

considered relatively small when compared to the total volume of water in the sanctuary (i.e., 

this wastewater becomes diluted once it is discharged), it is unlikely that this reduction in 

wastewater discharge would result in a significant improvement in water quality or biological 

resource health (i.e., an elevation from “good” to “excellent” rating for water quality in future 

condition reports). Thus, the beneficial effects to biological resources of modifying OCNMS 

discharge regulations under alternatives B and C would be less than significant. While the 

effects of changing the vessel discharge regulations under alternatives B and C may not be 

significant within the context of this NEPA analysis, these regulatory changes are still beneficial 

to biological resources. The goal of more stringent vessel discharge regulations under 

alternatives B and C would be a precautionary approach, which is fitting of a marine protected 
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area designated for its national significance, to reduce overall stress on sanctuary ecosystems, 

maintain existing good water quality conditions in the sanctuary, and prevent the future 

degradation of water quality that could occur should wastewater discharge increase in the 

sanctuary region.

8.2.2.3 Area-to-be-Avoided – Effects to the Biological Setting

Currently, the Olympic Coast Area to be Avoided (ATBA) is an International Maritime 

Organization (IMO) voluntary vessel routing measure. Under alternatives A and B, it would 

remain voluntary and continue to apply to all ships and barges carrying cargoes of oil or 

hazardous materials, and all ships 1,600 gross tons and above solely in transit. It would also 

apply to additional classes of vessels based on recent legislation. The Coast Guard Authorization 

Act for Fiscal Years 2010 and 2011 calls on NOAA to work with the USCG to revise the ATBA 

so existing restrictions apply to additional vessels. This change would apply to vessels between 

400 GT and 1,600 GT, other than fishing or research vessels while engaged in fishing or research 

within the area to be avoided.

Because the ATBA would continue as a monitored, voluntary measure without changes to the 

existing program, ATBA activities under alternatives A and B are expected to have a less than 

significant, beneficial, indirect, long-term effect on biological resources by keeping ships further 

offshore and shifting vessel traffic noise away from the continental shelf and much of the 

sanctuary. The effect is considered less than significant because, while the ATBA reduces the 

risk of a spill occurring in the sanctuary, it does not directly prevent spills from occurring and 

does not eliminate vessel traffic noise from the sanctuary. 

Under alternative C, OCNMS would work with its partners to evaluate options to make 

compliance with the ATBA mandatory. This could have an additional beneficial effect (beyond 

alternatives A and B) on physical resources.

In order to understand the extent and potential significance of this beneficial effect, OCNMS 

evaluated ATBA compliance rates and identified the population of vessels not voluntarily 

complying with the ATBA. OCNMS further evaluated responses from the ATBA Monitoring 

and Outreach program to evaluate response from industry on reasons for non-compliance. This 

analysis is discussed in 8.1.2.4.

This analysis concluded changing the ATBA provisions from voluntary to mandatory would 

have negligible effects on physical resources in the sanctuary, based on the level of observed 

cooperation by the maritime community and the lack of documented cases where mariners have 

elected to ignore the voluntary nature of the ATBA. In addition, modification of the ATBA 

would require submitting a U.S. government proposal to the Marine Safety Committee of the 

IMO. When considering vessel routing measures used for the purposes of environmental 

protection the IMO balances the need for natural resource protection with the protection of 

traditional freedoms of navigation. Given the current high rate of compliance NOAA does not 

believe a request to change the ATBA from voluntary to mandatory would be favorably 

received. For these reasons, the ATBA expansion is not included in OCNMS‟ preferred 

alternative. 
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8.2.2.4 Invasive Species Discharge Regulation – Effects to the Biological Setting

Under alternative C, ONMS would establish a new regulation banning the discharge of invasive 

species in the sanctuary, in addition to conducting a series of non-regulatory actions to address 

invasive species (detailed in the Habitat Protection Action Plan). Under alternatives A and B, 

this regulation would not be pursued, and the issue of invasive species would be addressed solely 

through non-regulatory actions. Section 8.2.2.1 provides analysis of the environmental 

consequences of these non-regulatory strategies.

Banning the introduction of invasive species in the sanctuary could have a beneficial, long-term, 

indirect effect on biological resources in the sanctuary. Invasive species can adversely impact 

other organisms in a number of ways, including outcompeting native species for habitat and food 

sources; spreading diseases to native species; altering the chemistry or physical structure of the 

environment in a way that inhibits the growth and health of native species; breeding with native 

species and thus causing alterations in native species genetics; and/or preying aggressively upon 

native species and thus causing reductions in native species populations. Different invasive 

species cause different, often unpredictable, effects in different ecosystems. 

By prohibiting the discharge of invasive species in the sanctuary, ONMS would be 

complementing state of Washington regulations aiming to prevent the introduction of invasive 

species into state waters. In most cases, the effects on biological resources of this new OCNMS 

regulation would be indirect because the regulation would prohibit discharge of organisms, 

effects of which would likely occur at locations and times removed from the initial introduction 

of the organism. 

The beneficial effect of this action on biological resources is assumed to be less than significant 

because the state of Washington already implements comprehensive ballast water and aquatic 

nuisance (invasive species) programs that dramatically reduce the risk of invasive species 

introduction within the sanctuary. Because of Washington state regulations outlined in section 

8.1.2.5, no ballast water discharges or exchanges should be occurring in the sanctuary (except of 

mid-ocean exchanged ballast water), and no release of potentially invasive species should be 

occurring in state waters within three miles of shore. Because an OCNMS regulation banning 

discharge of invasive species would not increase protections provided by existing state, federal, 

and Canadian regulations related to invasive species, this regulation was not included in the 

preferred management plan alternative (alternative B). 

8.2.3 Actions with Adverse Effects to the Biological Setting

Several non-regulatory actions being considered under alternatives A, B and C would result in 

some adverse effects to biological resources. Alternative A (i.e., continued management using 

the 1994 OCNMS management plan) does not define these actions in the level of detail provided 

under alternatives B and C. However, because the original 1994 OCNMS management plan is 

so broad and general in nature, this analysis assumes the adverse effects discussed below could 

occur under the alternative A.
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8.2.3.1 Conducting Wildlife Research, Assessments and Monitoring – Effects to the 

Biological Setting

Alternatives A, B and C consider a variety of wildlife research, assessment and monitoring 

actions in order to collect data on species, community and population status, health and trends. 

This information is critical to effective ecosystem management decision making by OCNMS and 

others. Wildlife research, assessments and monitoring actions in the sanctuary (under all three 

alternatives) could affect biota in the water column, as well as in benthic, intertidal and subtidal 

habitats. 

In many cases, conducting research, assessments and monitoring does not cause any adverse or 

beneficial effect to biological resources (e.g., using binoculars to count sea otters at a distance of 

100 – 200 yards). However, in some cases, actions taken while studying biota can cause direct, 

adverse impacts such as disturbance, minor injury or death. For example, seafloor habitat studies 

may require collection of organisms for species identification or age analysis. Flying over 

marine bird colonies for census purposes can disturb the birds. Research may involve tagging 

organisms, which causes minor, temporary injury to the organism.

Most wildlife studies in the sanctuary are designed and led by entities other than ONMS. 

OCNMS personnel assist with these efforts and, when appropriate, issue research permits for 

studies in the sanctuary. The primary exceptions to this are intertidal monitoring, deep sea coral 

investigations, and oceanographic monitoring buoys in the sanctuary, all efforts OCNMS staff 

routinely lead. Adverse effects of these activities are discussed in greater detail below. 

When applying for a sanctuary research permit, applicants must document how they will comply 

with all applicable federal and state laws, such as the Endangered Species Act and the Marine 

Mammal Protection Act. OCNMS staff reviews permit applications on a case-by-case basis and 

ensures adequate NEPA analysis (by the applicant or OCNMS) is conducted prior to permit 

issuance. In all cases, ONMS and its partner agencies ensure wildlife studies are designed to 

minimize the adverse impacts to biota. Particularly with studies of marine birds and mammals, 

researchers avoid or minimize wildlife disturbance to the greatest extent possible. In order to get 

an accurate census, aircraft are operated in a manner minimizing the intensity and duration of 

disturbance to the animals being studied. Thus, the adverse effects of these actions are assumed 

to be direct, but less than significant and short-term.

8.2.3.2 Operating Hydrographic Sonar in the Sanctuary – Effects to the Biological Setting

All three alternatives (A, B and C) consider actions utilizing sonar in support of hydrographic 

surveying (seafloor mapping) of the sanctuary. Hydrographic survey data collection in the 

sanctuary uses active sonar in varying frequency ranges to map the seafloor. These systems are 

typically either hull-mounted multibeam or towed side-scan sonar systems. Active sonar devices 

emit pulses of sound waves that travel through the water, reflect off objects, and return to a 

receiver on the ship. Recent, comprehensive analyses of impacts of anthropogenic underwater 

noise on marine mammals (e.g., Southall et al. 2007) address sound sources likely to be more 

egregious, such as explosions, pile driving, seismic air guns, and military low- and midfrequency sonar, but do not specifically address of sonar systems used for seafloor mapping. 

Anthropogenic underwater sounds can adversely affect marine animals in several ways. 

Response effects on marine mammals are manifest in behavioral changes, such as alteration of 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

their foraging, diving or vocalization patterns. More intense sound sources can cause physical 

damage to marine animals, such as damage to sound receiving tissues. 

Evaluation of the potential for hydrographic survey sonar to impact marine animals must consider 

1) exposure to the sound waves, 2) ability to detect the sound frequency, and 3) intensity of sound 

exposure. The echosounders most frequently used for coastal surveys within OCNMS are highfrequency echosounders operating at 100-500 kHz (Table 16). One multibeam system (Reson 

Seabat 8160) used for mapping deep areas operates at a lower frequency (50 kHz), which is 

considered high-frequency sonar (i.e., >10 kHz). The Reson 8101 multibeam echosounder is 

installed on OCNMS‟ RV Tatoosh and the Reson 7125 is installed on Office of Coast Survey 

launches conducting the majority of multibeam survey work in OCNMS.

Table 16 Echosounder specifications for equipment most commonly used by OCNMS for hydrographic 

surveys

Echosounder Frequency (kHz) Transmit Beam Width Across Track

L-3 Klein 3000 (towed dual frequency side scan sonar) 100/500 40°

Reson 7125 (multibeam sonar) 200/400 150°

Klein 5000 (towed side scan sonar) 455 ~

Reson Seabat 7111 (deep water multibeam sonar) 100 150°

Reson Seabat 8101 (deep water multibeam sonar) 240 150°

Reson Seabat 8160 (deep water multibeam sonar) 50 150°

Kongsberg Simrad EM1002 (deep water multibeam sonar) 95 150°

There is a low probability of marine mammal exposure to sonar from a side-scan “fish” because 

during operation the instruments are towed near the seafloor, typically 10-20 m off the bottom, 

with sound directed downward. To intersect with a side-scan‟s zone of sonification, a marine 

mammal would have to swim under the side scan “fish” very near the seafloor. Multibeam sonar 

systems are typically hull mounted and have a wide beam width (Table 16), so their sonar 

transmits throughout the water column over a sizeable area underneath the survey vessel; 

therefore, the area of potential exposure is significantly larger for multibeam than with sidescan 

sonar. Both systems emit relatively low intensity sound in comparison to underwater detonations 

or military low- and mid-frequency sonar used to traverse long distances under water. Highfrequency sonar attenuates through scattering and absorption in water, an effect that increases 

with sonar frequency. Thus, these higher frequency sonar systems have potential to expose 

animals to low intensity sound in a limited area between the instrument and the seafloor.

Marine mammals have been categorized into low-, mid-, and high-frequency functional hearing 

groups (Southall et al. 2007). Mid-frequency cetaceans have an upper limit of sound detection of 

160 kHz. High-frequency cetaceans can detect up to 180 kHz. Pinnipeds in water cannot detect 

sounds above 75 kHz. In a recent and comprehensive analysis of potential impacts to marine 

mammals of sonar and underwater noises, the U.S. Navy (2010b) did not model impacts of sonar 

systems operating above 180 kHz because marine mammals have functional hearing ranging 

from 10 hertz (Hz) to 180 kHz, and they are most sensitive to sound sources well below 180 
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kHz. Marine fish generally have hearing capability at frequencies of 4 kHz or lower (U.S. Navy 

2010b), well below frequencies used for hydrographic surveys. 

Because sound generated by hydrographic survey equipment has a low intensity level, occurs 

over a limited area, attenuates quickly, and is at frequencies out of peak hearing ranges for most 

marine mammals, the likelihood of adverse effects to marine life is very low.

NOAA continues to refine its understanding of each species‟ sensitivity to sound with the goal of 

minimizing adverse effects to marine organisms. ONMS believes its use of sonar in support of 

hydrographic surveying has a less than significant, short-term, direct adverse effect on organisms 

(particularly marine mammals) in the sanctuary. 

In general, the ocean is becoming a much noisier place and concern about the cumulative effects 

of underwater noise pollution is increasing. The potential cumulative effects of noise pollution 

in the sanctuary are discussed in section 8.5.

8.2.3.3 Seabed Disturbance from Research Activities – Effects to the Biological Setting

Alternatives A, B and C consider research, monitoring and assessment actions related to habitat 

studies and mapping and oceanographic monitoring that may necessitate disturbance of the 

seafloor in the sanctuary. Because virtually all seafloor substrates in the sanctuary host some 

living organisms, disturbing the seafloor can adversely affect biological resources. Seafloor 

disturbance would occur when:

 Anchoring water quality and oceanographic monitoring buoys

 Collecting benthic sediment samples to support habitat mapping and characterization 

efforts and to identify infaunal communities

Similar to adverse effects to the physical setting, adverse effects to the biological resources 

caused by buoy anchors are direct but less than significant, for several reasons. The anchors are 

relatively small in size (Figure 14) and few in number, so they impact a miniscule percentage of 

sanctuary seafloor. Anchors are deployed on soft rather than rocky seafloor, and soft seafloor 

habitats are more disturbance tolerant and biological resources there would likely recover more 

quickly than hard seafloor habitats. Moreover, the anchors generally remain in place without 

dragging and disturbing a large area of seafloor. Surface dwelling organisms may be crushed 

when the weights are deployed, and subsurface organisms may be blocked from access to 

overlying water. Most macrofauna inhabiting seafloor substrate is located in the upper, 

oxygenated layer of sediment. These effects are short-term because the anchors are retrieved, 

and it is expected the soft seafloor habitats where the anchoring occurs are repopulated with 

biological organisms relatively quickly (within a year) following this disturbance. If the 

connection to the mooring floats is broken, there is a risk that weights could be abandoned,

which would cause long-term effects. These effects are less than significant because the area 

impacted is small, the anchors are constructed of non-toxic materials for the anchor weights, and 

anchors are lost infrequently. 

Similar to adverse effects to the physical setting, the adverse effects to biological resources 

caused by benthic sediment sampling are expected to be direct and less than significant because 

the sampling devices impact a small area of the seafloor (generally 0.1m2or less) in areas of 

sedimentation (not hard substrate), and sampling is conducted at wide spatial and temporal 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

intervals. The organisms inhabiting the sediment sample normally are collected and analyzed, 

and they do not survive. While a few organisms may die, the overall populations of these 

organisms are not likely to be affected adversely because a minuscule area of the seafloor is 

sampled on an occasional basis. 

Figure 14 OCNMS mooring anchor

Collection of sediment samples allows ONMS to refine its habitat mapping and classification 

methods to rely less on physical sediment sampling in the future. This work also improves 

understanding of organism distribution relative to different sediment types or areas. The effects

of this sediment sampling are short-term given the limited area impacted and types of substrates 

targeted. If seafloor sampling activities inadvertently impact hard substrate, long-term effects 

may result – particularly if coral/sponge habitat is damaged because this habitat recovers slowly. 

However, this is not a planned activity, the damage is not anticipated, and the extent is expected 

to be de minimis. 

8.2.3.4 Operating Vessels in Sanctuary – Effects to the Biological Setting

Several actions being considered under alternatives A, B and C involve the operation of vessels 

in the sanctuary, which has the potential to cause direct and indirect adverse effects to biological 

resources. These actions include:

 On-water enforcement activities

 Research, monitoring and assessment activities

 Outreach and education activities
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OCNMS vessel operations are described in section 8.1.3. OCNMS vessels contribute to noise 

and air pollution in the sanctuary, can collide with marine life, and pose a risk of hazardous 

materials spills or of sinking, all of which could affect biological resources. In addition, 

operation of vessels has the potential to adversely affect marine life through vessel strikes or 

disturbance to animals. 

The release of hazardous materials from an OCNMS vessel sinking would have the potential to 

adversely affect the biological environment through compromised water quality. The risk of a 

hazardous materials spill or vessel sinking is low because these vessels are maintained and 

operated according to rigorous NOAA safety guidelines, have a good safety record, and carry 

relatively small amounts of hazardous materials (fuels and fluids). Since OCNMS designation, 

no OCNMS-owned or contracted vessel has been responsible for a hazardous materials spill.

Noise pollution can cause both direct biological effects (e.g., distract an organism from its 

current path) and indirect effects (e.g., alter behavior paths in a manner that reduces access to 

food sources). If noise from human activities is elevated to levels considered “pollution” or 

chronic disturbance, it is more likely to result from the cumulative effect of all vessels operating 

in the sanctuary, including the numerous vessels not operating on behalf of ONMS. The 

cumulative effects of noise pollution are discussed in section 8.5. 

Vessel captains operate with sensitivity to avoid disturbance or injury to marine life. Given the 

relatively small size of OCNMS vessels, vessel captains are acutely concerned about collisions 

with floating objects (i.e., logs, floats), seabirds (which can be sucked into the engine water 

intakes or clog the propulsion jets), and marine mammals. On water visibility from OCNMS 

vessels is excellent, and operations are limited to daylight in moderate seas, which provides 

better marine mammal sighting conditions. Moreover, vessel captains are trained to watch for 

marine mammals and seabirds and maneuver the vessel away from them. All of these conditions 

support a low risk of vessel strikes. The severity of vessel strikes, the conservation status of the 

species hit and the number of vessel strikes in a given year are all factors influencing the 

significance of vessels strikes as a potential adverse effect. Twenty-nine species of marine 

mammal have been sighted in the sanctuary, eight of which are listed on the Endangered Species 

List. In its 16-year history, no OCNMS owned or contracted vessel has struck a marine mammal

or been responsible for a hazardous materials spill. 

Because OCNMS vessels and those acting on behalf of OCNMS operate in the sanctuary an 

average of a few hundred hours per year with operations widely distributed in space and time, it 

is expected that the effects on biological resources of vessel operations is less than significant. 

Under all three alternatives, the potential effects of operating OCNMS research vessels on 

biological resources would be considered less than significant, direct (a vessel strike or fuel spill) 

and indirect adverse effects on the population of the species affected. 

8.2.3.5 Conducting Activities in Intertidal Areas – Effects to the Biological Setting

Alternatives A, B and C also consider actions potentially causing adverse effects to shore and 

intertidal biological resources. These actions include:
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 Beach and intertidal educational and interpretive programs

 Intertidal monitoring surveys

 Marine debris removal projects

 Encouraging visitation to beaches and intertidal areas

Actions in the intertidal zone may have direct, but less than significant, adverse effects on 

biological resources. Intertidal educational and interpretive programs typically involve small 

groups traversing intertidal habitat and can trample invertebrates and algae on rocky surfaces. 

Interpretive efforts encouraging visitation to beaches and intertidal zones can also lead to 

trampling. Intertidal survey teams also can cause trampling damage. Marine debris removal 

sponsored by OCNMS and its partners can cause disturbance of intertidal habitats, or result in 

debris being dragged along the shore, thus causing disturbance. 

These adverse effects are less than significant because the disturbance to biological organisms 

occurring is widely distributed in space and time and generally limited because there are small 

groups of people. Moreover, participants in OCNMS stewardship, interpretive, educational and 

research programs generally are instructed on proper beach etiquette and ways to minimize their 

impacts on intertidal habitats. The purpose of these actions is to improve ocean literacy, educate 

people on becoming better stewards of ocean ecosystems, reduce the impacts of marine debris, 

and improve our understanding of intertidal community ecology – all of which are outcomes 

beneficially influencing long-term efforts to protect these resources. These overwhelmingly 

beneficial effects of these activities outweigh the minimal adverse effects that may occur.

8.2.4 Summary of Effects to Biological Resources

Within the context of this NEPA analysis, the majority of actions being considered under 

alternatives A, B and C would have a primarily beneficial, less than significant effect on 

biological resources in the sanctuary. This is because many of the actions, while important to 

achieving OCNMS‟ goals and objectives, are relatively small in scale and are not expected to 

cause a significant improvement to biological resources over the life of the management plan 

(five to ten years). There is not a substantive difference in the beneficial effects to biological 

resources of the three alternatives. Alternative C would have a greater overall beneficial effect 

on biological resources, due to the several additional regulatory and non-regulatory actions it 

considers, but this effect would not be significant.

Several adverse effects to biological resources are associated with the actions being considered 

under the three alternatives, but none of the effects would be significant. There is not a 

substantive difference between the adverse effects to biological resources of the three 

alternatives. 
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8.3 HISTORICAL/CULTURAL SETTING

8.3.1 Actions with Negligible Effect to the Historical/Cultural Setting

There are several actions occurring under all three alternatives expected to have a negligible 

effect on the historical/cultural setting. These actions include:

 Structural changes to the format of the OCNMS management plan, and revisions to 

OCNMS goals and objectives

 Routine office and classroom activities, including meetings, visitor, education and 

training programs that take place in existing OCNMS or other facilities

 Use of Information Technology resources, including internet technology, data 

management programs, phone and e-mail technology

 Routine outreach activities that do not occur in the sanctuary, including staffing fair 

booths and attending community events

 Evaluate options to make compliance with the ATBA mandatory

 Including a new regulation to ban discharge of invasive species

 Expanding discharge regulation to include ban on cruise ship discharge

 Expanding discharge regulation to include ban on large vessel discharge

 Operating vessels in sanctuary

 Encouraging visitor use of beaches and intertidal areas

 Routine research activities

 Conducting wildlife research, monitoring and assessments

 Beach and intertidal activities (student field trips, beach debris removal)

These actions are expected to have a negligible effect on the historical/cultural because they 

involve no direct or indirect interaction between people or equipment and historical/cultural 

resources, are administrative in nature, occur within existing facilities, or include no construction 

or physical development. The actions identified above that could potentially occur in the vicinity 

of historical/cultural resources – research activities, wildlife monitoring, beach/intertidal 

activities - are conducted by (or under the supervision of) sanctuary staff with sensitivity to their 

responsibility under the National Historic Preservation Act. Activities involving physical 

disturbance to the terrestrial or marine substrate are evaluated in advance for proximity to 

locations in the SHPO‟s database, and they are not conducted in the immediate vicinity of 

documented historical/cultural resources. If an undocumented resource is identified or 

suspected, sanctuary staff would cease operations and consult with the SHPO and THPO before 

additional disturbance would be allowed. Furthermore, in Strategy MH1 of the management 

plan OCNMS has identified as a high priority the development of a programmatic agreement that 

will clarify and formalize procedures for consultation with other historical/cultural resource 

managers and avoidance of impacts to these resources. 

There are several actions proposed under alternatives B and C involving modifications to 

OCNMS regulations which also have negligible effects on the historical/cultural setting. These 

include: 

 Technical clarifications to OCNMS regulations as outlined in the Sanctuary Operations 

Action Plan (strategy OPS 9, activity H)
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 Replace the term “traditional fishing” with “lawful fishing”

 Modifications to the tribal welfare permit provision in the OCNMS regulations

 Reducing the OCNMS overflight regulation from 2,000 feet to 1,000 feet (alternative C

only)

The technical clarifications to OCNMS regulations would not affect historical/cultural resources

within the sanctuary because the changes are language clarifications not altering the meaning or 

intent of the regulations. 

The current OCNMS regulations define the term “traditional fishing” as “using a fishing method 

that has been used in the sanctuary before the effective date of sanctuary designation (July 22, 

1994), including the retrieval of fishing gear” and provide an exception for traditional fishing 

operations to three of the regulatory prohibitions – prohibitions on discharge of certain fishingrelated materials, disturbance to historical resources, and disturbance to the seabed. OCNMS 

regulations could be interpreted to mean that fishing methods or operations that do not fall within 

the definition of “traditional fishing” are not allowed to discharge materials mentioned above, or 

disturb historical resources or the seabed. 

As part of this action, NOAA proposes to replace the term “traditional fishing” with the term 

“lawful fishing” in these three places to: 1) use a more clearly understood; and 2) eliminate the 

distinction between fishing methods used before OCNMS designation from those authorized 

after designation. By replacing the word “traditional” with “lawful” NOAA would 

unambiguously recognize fishing activities authorized by governmental fisheries management 

authorities. This change is expected to have a negligible effect because Federal, state, tribal and 

regional fishery management authorities currently analyze and attempt to mitigate impacts 

associated with lawful fishing, including that which has occurred traditionally in the sanctuary, 

and those authorities are expected to do the same in the future. Since the scope and impacts of 

any such future management actions are speculative at this point, it is not possible, and would be 

inappropriate, to speculate on any additional impact analysis in this document. See section 8.1.1 

for more discussion on the regulatory change to replace the phrase “traditional fishing” with 

“lawful fishing”. 

Under the current regulations, OCNMS can issue a permit to conduct an activity otherwise 

prohibited if it finds that the activity will meet criteria identified in the regulations. One of the 

criteria listed for permit issuance is to “promote the welfare of any Indian tribe adjacent to the 

sanctuary.” This provision is ambiguous and could be interpreted as allowing an entity not 

affiliated with a tribe to apply for a permit that it alleges could promote the welfare of an Indian 

tribe adjacent to the sanctuary. By modifying the tribal welfare permit language, OCNMS is 

clarifying the intent of its regulations to ensure it is used to promote or enhance tribal selfdetermination and not to be used by outside parties. Because this regulatory change does not 

alter the availability of this permit category to American Indian tribes adjacent to the sanctuary, 

nor change the requirement that the permitted activity will not substantially injure Sanctuary 

resources and qualities, this modification to the permitting regulations is expected to have a 

negligible effect on the historical/cultural setting. See section 8.1.1 for more discussion on the 

regulatory change to clarify the permitting language.
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A lowering of the overflight floor from 2,000 feet to 1,000 feet would not affect 

historical/cultural resources within the sanctuary because this change in regulation would not 

affect the number or type of aircraft flying over the sanctuary and flights will not have physical 

interaction with maritime heritage resources.

Finally, alternatives B and C also contain some structural changes to the management plan not 

included in alternative A. Under alternatives B and C, the management plan would contain 

performance measures, cost estimates and an implementation table. Alternatives B and C also 

would include a revised suite of goals and objectives for OCNMS. While these structural 

modifications to the document would have a negligible effect on the historical/cultural setting, 

they are important to note because these modifications do provide additional clarity and detail to 

alternatives B and C.

8.3.2 Actions with Beneficial Effects to the Historical/Cultural Setting

There are several activities occurring in one or more of the alternatives expected to have a 

beneficial effect on historical/cultural resources within the sanctuary. These actions include:

 Routine education, outreach visitor service, resource protection and administrative

origran activities

 Operating sonar (for hydrographic surveying)

 Routine maritime heritage activities

8.3.2.1 Routine Education, Outreach, Visitor Services, Resource Protection and 

Administrative Program Activities – Effects to the Historical/Cultural Setting

Many of the routine education, outreach, visitor services, resource protection and administrative 

actions taking place under all three alternatives would have an indirect, short-term, and less than 

significant, beneficial effect on historical/cultural resources within the sanctuary. These routine 

actions involve the continuation of OCNMS‟ primary program areas, including:

 Routine resource protection activities (e.g., beach cleanups)

 Routine outreach activities (e.g., public events)

 Routine education activities (e.g., maritime heritage presentations)

 Routine visitor services activities (e.g., operating Olympic Coast Discovery Center)

 Routine administrative activities (e.g., enforcement of regulations and permitting)

All of these program areas have less than significant, indirect and beneficial effects on 

historical/cultural resources because they promote ocean and cultural resource literacy, 

improved understanding and protection of heritage resources, and improved ocean stewardship. 

By promoting these principles with partners, local communities and the general public, OCNMS 

has the opportunity to influence the behavior and decision-making of individuals, communities, 

organizations and agencies in ways benefiting historical/cultural resources. For example, if a 

citizen visits an OCNMS fair booth and learns about the importance of not disturbing 

archaeological remains, s/he may be more likely to act responsibly near historic/cultural 

resources. They might also share that perspective with others, which could result in better 

protection of resources, such as shipwreck remains or shoreline midden sites.
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While these routine actions are beneficial, it is not expected their effects would be significant

within the context of NEPA. The expected implementation period of the management plan is 

not expected to be more than 10 years. It is not likely that a substantial improvement in 

historical/cultural resources could be achieved on such a short timeframe as a result of these 

types of indirect, beneficial actions. 

8.3.2.2 Operating Sonar for Hydrographic Surveying – Effects to the Historical/Cultural 

Setting

Section 110 of the National Historic Preservation Act (NHPA) directs federal agencies 

managing public bottomlands to inventory the historical and archaeological resources within 

the management areas and to assess the significance of those resources for possible inclusion 

onto the National Register of Historic Places. Under all three alternatives considered, 

operating sonar for hydrographic surveying would be conducted to identify and map habitats, 

as well as biological and historical resources. This activity would have a beneficial, indirect, 

and less than significant effect on historical/cultural resources because they would improve 

understanding of what historic and cultural resources exist in the sanctuary. Improved 

understanding of resources alone may not directly affect these resources in a beneficial way. 

However, subsequent actions resulting from this research, such as listing on the National 

Register of Historic Places, would benefit the resources in the long term. The beneficial effect 

of these research activities is expected to be less than significant because there is no assurance 

that resources will be found or that they can be effectively protected in the harsh sanctuary 

environment. 

8.3.2.3 Routine Maritime Heritage Activities – Effects to the Historical/Cultural Setting

As noted above, Section 110 of the NHPA requires agencies to inventory historical and 

archaeological properties. ONMS is also directed by the National Marine Sanctuaries Act to 

comply with the Federal Archaeology Program which includes laws, regulations and guidelines 

administered by the Department of the Interior. The Secretary of Interior's Standards and 

Guidelines for Archeology and Historic Preservation (48 FR 44716) recommend the following 

activities to inventory historical and archaeological properties:

 Identification of the resources through:

o Archival Research - the OCNMS database contains much of this research

o Field Survey – beach surveys and remote sensing of submerged sanctuary 

environment

o Reporting of Results – results should be reported upon to professional 

communities and the public

 Evaluation of identified resources to determine the historical significance of the resource

 Registration of significant resources to the National Register of Historic Places and, if 

appropriate, as a National Historic Landmark

Actions outlined in section 5.2 in Strategy MH1 – Cultural Resource Conservation are expected 

to have a beneficial effect on historic and cultural resources because they will improve 

knowledge and understanding of these resources and thus indirectly improve OCNMS‟ ability to 

protect and interpret these resources. Additionally, should resources be identified and eligible 

for the National Register of Historic Places, this designation would provide added protections for 

the resources. OCNMS expects the effects of these actions on cultural resources to be less than 
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significant because they consist exclusively of planning and low-impact survey activities for 

beneficial conservation purposes. As part of the implementation of the final management plan, 

OCNMS will work with the State Historic Preservation Office (SHPO), Makah Tribal Historical 

Preservation Office (THPO), and other partners to develop a programmatic agreement under 

section 106 of the National Historic Preservation Act. This process is likely to provide NOAA 

with a better understanding of the current status of historic resources within the sanctuary. 

Should significant historic resources be found in the sanctuary, OCNMS will work with the same 

partners to develop appropriate management plans for these resources in accordance with NEPA 

and NHPA. 

8.3.3 Actions with Adverse Effects to the Historical/Cultural Setting

Several actions being considered under alternatives A, B and C could result in adverse effects to 

historical/cultural resources in the sanctuary. These include the following actions that may 

necessitate disturbance of the seafloor in the sanctuary:

 Anchoring water quality and oceanographic monitoring buoys

 Collecting benthic sediment samples to support habitat mapping and characterization 

efforts and to identify infaunal communities

These actions are described in section 8.1.3. Both actions have the potential for damaging 

historical/cultural resources on the seabed. The impacts described in section 8.1.3 (impacts to 

physical setting) apply here. These activities could cause adverse effects to historic/cultural 

resources by physically damaging historic resources resting on the seafloor of which OCNMS is 

unaware. Because these operations impact only the upper few centimeters in a very limited area 

on the seafloor and the total area subject to these operations is small over a 5- to 10-year period, 

these effects would be less than significant.

It should be noted these two actions (sediment sampling and anchoring buoys) refer to OCNMS 

efforts only. It is possible an outside party could apply for an OCNMS permit to conduct sediment 

sampling, anchor research buoys or conduct some other seafloor disturbance activity in the 

sanctuary on a scale larger than work conducted by OCNMS. Permit applications of this kind will

be analyzed for potential impacts to historic and cultural resources (as well as biological and 

physical resources). OCNMS might deny or place specific restrictions on a permit in order to 

ensure the protection of resources (see 8.5 Cumulative Effects, Actions for Future Analysis). 

8.3.3.1 Compliance with Section 106 of the NHPA – Effects to the Historical/Cultural 

Setting

On April 27, 2010, ONMS published a Federal Register notice (Appendix B) notifying the public 

of ONMS‟ intent to coordinate its responsibilities under Section 106 of NHPA with its ongoing 

NEPA process, including the use of NEPA documents and public and stakeholder meetings to meet 

the NHPA Section 106 requirements. Section 8.3 of this document addresses the 

“Historical/Cultural Setting” and is intended to fulfill NHPA Section 106 requirements for the 

revised OCNMS management plan. It should be noted that Section 106 of NHPA addresses only 

historic properties and resources as defined in the NHPA. The analysis in this document 

encompasses additional cultural resources that are included in order to satisfy NEPA analysis 

requirements.
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In the process of developing this document, ONMS identified consulting parties and requested 

information about historic properties and resources in the sanctuary to be considered in this impacts 

analysis. No information was provided by the SHPO, THPO or others during the EA drafting 

process. Should more information on the effects of revising the management plan on historic 

resources and properties come to light once the FMP/EA is published, OCNMS will consult with 

the SHPO and THPO and conduct its operations consistent with NHPA requirements.

8.3.4 Summary of Effects to Historical/Cultural Setting

In general, the majority of actions being considered under alternatives A, B and C would have a 

primarily beneficial, less than significant effect on historical/cultural resources in the sanctuary. 

The effects are expected to be less than significant because many of the actions, while important 

to achieving OCNMS‟ goals and objectives, are relatively small in scale and are not expected to 

cause a significant improvement to historical/cultural resources over the life of the management 

plan (five to ten years). There is not a significant difference between the beneficial effects to 

historical/cultural resources of the three alternatives. 

Regarding adverse effects to historical/cultural resources, some are associated with actions being 

considered under the three alternatives, but none of these adverse effects would be significant. 

There is not a significant difference between the adverse effects to historical/cultural resources of 

the three alternatives. 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

8.4 HUMAN/SOCIOECONOMIC SETTING

The purpose of this section is to discuss the socioeconomic effects of all three alternatives on 

human activities. An overview of the sanctuary‟s human/socioeconomic setting and the 

activities encompassed within this setting is provided in the Affected Environment discussion.

If the no action alternative (alternative A) were selected, ONMS could choose to implement the 

non-regulatory aspects of alternatives B and C, which would have unique implications on the 

human/socioeconomic setting. Because the extensive efforts in collaboration with multiple 

partners were made through the management plan review process to evaluate OCNMS programs 

and more clearly define future priorities, an expectation has developed amongst collaborators 

that most all of the action plans will be implemented. Given the lack of specificity in the current 

management plan, which represents the no action alternative, it is likely that OCNMS would 

seek to implement many non-regulatory actions in alternative B under the no action alternative. 

Yet implementation of these action plans without officially adopting them through revision to the 

management plan would undermine the trust developed through this process and transparency 

that ONMS aims to achieve with the management plan review process. Implementing the action 

plans without incorporating them into an OCNMS management plan would reduce ONMS‟ 

accountability and most likely confuse members of the public interested in understanding 

ONMS‟ structure and work efforts. Moreover, because the 20 action plans in the FMP do not 

correspond directly to the structure of the original 1994 management plan, it would be difficult 

for the public and ONMS partners to understand how the action plans and original management 

plan relate to one another.

8.4.1 Actions with Negligible Effects to the Human/Socioeconomic Setting

There are several actions occurring under all three alternatives that are expected to have a 

negligible effect on the human/socioeconomic setting within or around the sanctuary. These 

actions include:

 Structural changes to the format of the OCNMS management plan, and revisions to 

OCNMS goals and objectives

 Routine office and classroom activities, including meetings, visitor, education and 

training programs that take place in existing OCNMS or other facilities

 Use of Information Technology resources, including internet technology, data 

management programs, phone and e-mail technology

 Routine outreach activities that do not occur in the sanctuary, including staffing fair 

booths and attending community events

None of these actions would have a direct impact on human activities within the sanctuary. 

These actions are either administrative in nature or do not involve any direct or indirect 

interaction between the people conducting the actions and human activities within the sanctuary. 

Other actions proposed under alternatives B and C involving modifications to OCNMS 

regulations would also have negligible effects on the historical/cultural setting. These include: 

 Technical clarifications to OCNMS regulations as outlined in the Sanctuary Operations 

Action Plan (strategy OPS 9, activity H)
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

 Replacing the term “traditional fishing” with “lawful fishing”

 Modifications to the tribal welfare permit provision in the OCNMS regulations

The technical clarifications to OCNMS regulations proposed in alternatives B and C would have 

negligible effects on the human/socioeconomic setting within or around the sanctuary because 

the changes are language clarifications that do not alter the meaning or intent of the regulations. 

The current OCNMS regulations define the term “traditional fishing” as “using a fishing method 

that has been used in the sanctuary before the effective date of sanctuary designation (July 22, 

1994), including the retrieval of fishing gear” and provide an exception for traditional fishing 

operations to three of the regulatory prohibitions – prohibitions on discharge of certain fishingrelated materials, disturbance to historical resources, and disturbance to the seabed. OCNMS 

regulations could be interpreted to mean fishing methods or operations not falling within the 

definition of “traditional fishing” are not allowed to discharge materials mentioned above, or 

disturb historical resources or the seabed. 

As part of this action, NOAA proposes to replace the term “traditional fishing” with the term 

“lawful fishing” in these three places to: 1) use a more clearly understood term; and 2) eliminate 

the distinction between fishing methods used before OCNMS designation from those authorized

after designation. By replacing the word “traditional” with “lawful” NOAA would 

unambiguously recognize fishing activities authorized by governmental fisheries management 

authorities. This change is expected to have a negligible effect because Federal, state, tribal and 

regional fishery management authorities currently analyze and attempt to mitigate impacts 

associated with lawful fishing, including that which has occurred traditionally in the sanctuary, 

and those authorities are expected to do the same in the future. Since the scope and impacts of 

any such future management actions are speculative at this point, it is not possible, and would be 

inappropriate, to speculate on any additional impact analysis in this document. See section 8.1.1 

for more discussion on the regulatory change to replace the phrase “traditional fishing” with 

“lawful fishing”. 

Under the current regulations, OCNMS can issue a permit to conduct an activity otherwise 

prohibited if it finds that the activity will meet criteria identified in the regulations. One of the 

criteria listed for permit issuance is to “promote the welfare of any Indian tribe adjacent to the 

sanctuary.” This provision is ambiguous and could be interpreted as allowing an entity not 

affiliated with a tribe to apply for a permit that it alleges could promote the welfare of an Indian 

tribe adjacent to the sanctuary. By modifying the tribal welfare permit language, OCNMS is 

clarifying the intent of its regulations to ensure it is used to promote or enhance tribal selfdetermination and not to be used by outside parties. Because this regulatory change does not 

alter the availability of this permit category to American Indian tribes adjacent to the sanctuary, 

nor change the requirement that the permitted activity will not substantially injure Sanctuary 

resources and qualities, this modification to the permitting regulations is expected to have a 

negligible effect on the human/socioeconomic setting. See section 8.1.1 for more discussion on 

the regulatory change to clarify the permitting language.

Alternative C would include a ban on the discharge of invasive species in the sanctuary. ONMS 

is unaware of any current human activities in the sanctuary involving or in any way requiring 

the discharge of invasive species other than open ocean aquaculture, which is addressed in 
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section 8.4.3.4. Ballast water discharge in the sanctuary is already prohibited by the state of 

Washington ballast water discharge regulations (except mid-ocean exchanged ballast water). 

Thus, an OCNMS invasive species discharge ban would have no additional socioeconomic effect 

on the shipping industry. Moreover, an OCNMS invasive species discharge ban would not 

require ship operators to conduct any additional vessel inspections or ballast water analyses. 

Thus, it is assumed there would be no socioeconomic effect on commercial or recreational 

fishing operations in the sanctuary from the enactment of an invasive species discharge ban.

Finally, alternatives B and C also contain some structural changes not included in alternative A. 

Under alternatives B and C, the management plan would contain performance measures, cost 

estimates and an implementation table. Alternatives B and C also would include a revised suite of 

goals and objectives for OCNMS. While these structural modifications would have a negligible 

effect on the human/socioeconomic setting in the sanctuary, they are important to note because 

these modifications do provide additional clarity and detail to alternatives B and C. 

8.4.2 Actions with Beneficial Effects to the Human/Socioeconomic Setting

There are several actions occurring in one or more of the alternatives expected to have a 

beneficial effect on human/socioeconomic setting within and around the sanctuary. These actions 

include:

 Routine activities conducted as part of OCNMS‟ resource protection, research, visitor 

services, outreach, education, vessel operations, maritime heritage and administrative 

program areas

 Beach and intertidal activities (student field trips, beach debris removal)

 Encouraging visitor use of beaches and intertidal areas

 A regulatory ban on cruise ship discharge (alternatives B and C)

8.4.2.1 Routine Activities

Many of the routine and general education, outreach, research, resource protection, 

administrative, maritime heritage and visitor services actions taking place under all three 

alternatives would have an indirect, short-term, less than significant and beneficial effect on the 

human/socioeconomic setting within the sanctuary. These routine actions involve the 

continuation of OCNMS‟ primary program areas, including:

 Resource protection and stewardship activities

 Research activities, including anchoring research buoys

 Operating sonar and sediment sampling (for hydrographic surveying)

 Routine outreach activities, including encouraging visitor use of the shoreline

 Routine education activities

 Vessel operations

 Maritime heritage activities

 Routine visitor services activities 

 Routine administrative activities 

These program areas are expected to have less than significant, indirect, and beneficial effects on 

the human/socioeconomic setting because they would advance regional ocean governance 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

through improved coordination and collaboration, and improve the value of the sanctuary for 

educational and research activities. Providing education programs and curricula to schools in 

disadvantaged communities on the outer coast could provide an economic benefit to those 

communities, which otherwise might have to fund development of such education programs or 

curricula. Additionally, providing signage and interpretive programs about the sanctuary could 

provide an economic benefit to local communities by enhancing tourism opportunities. While all 

of these routine actions would be beneficial, it is not expected their effects would be significant. 

The expected implementation period of the management plan is no more than 10 years; thus, the 

actions proposed within all three management plan alternatives are not projected to last longer 

than 10 years. It is not likely a significant improvement on the human/socioeconomic setting 

would be achieved on such a short timeframe as a result of these types of indirect beneficial 

actions. 

Additionally, it should be noted the very existence of the sanctuary and its routine work

programs have a beneficial and intangible effect on the human environment not measurable in 

dollars without conducting a complex and costly economic study of the non-use values of the 

sanctuary. This was deemed unnecessary by NOAA given the expected low negative impact of 

the proposed actions on the human/socioeconomic setting. In simple terms, OCNMS has both 

ecological and aesthetic values. The ecosystem provides ecological services that benefit human 

beings (e.g., primary productivity at the base of the marine food web). In addition, the sanctuary 

is a place where people can visit and experience a marine environment in a relatively 

undeveloped condition, with terrestrial wilderness at their back and the vast Pacific Ocean 

stretching beyond the horizon. Such experiences have an unquantifiable intrinsic value. Under 

all three alternatives, the intrinsic societal benefit of maintaining the sanctuary‟s programs, while 

difficult to quantify, is an important consideration. 

For nonconsumptive users and passive users, ecosystem conditions are important for determining 

benefits. Resource protection is known to change the status of the habitats protected and often 

results in positive changes to community structure and increased biodiversity. One of the main 

benefits is protection of a naturally functioning ecosystem (i.e., a more natural system minimally 

influenced by human beings) that is expected to have benefits for passive and nonconsumptive 

users. Naturally functioning marine ecosystems composed of diverse biological assemblages are 

hypothesized to be more likely to adapt to the increasingly acidic ocean conditions expected as a 

result of climate change, and are perhaps less likely to develop hypoxic conditions. Should this 

hypothesis be correct, the socioeconomic benefits to passive and nonconsumptive users of 

protecting naturally functioning marine ecosystems such as OCNMS would be substantial. 

Additionally, the resulting resilience of the sanctuary ecosystem, in combination with greater 

public awareness of this resilience through OCNMS education and outreach programs, can be 

expected to further increase benefits flowing to passive and non-consumptive users over time. 

Passive and nonconsumptive user groups may even have a willingness to pay for these increased 

benefits. Even if the per capita socioeconomic benefit to passive and nonconsumptive users of 

these ecosystem services is relatively small, the overall magnitude of these benefits is still 

potentially large. The probable size of the passive user community is in the order of many 

millions of users throughout Washington State and the nation, and the cost of passive use is 

generally small relative to other use costs. 
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8.4.2.2 Cruise Ship Discharges – Effects to the Human/Socioeconomic Setting

Representatives from the North West & Canada Cruise Association polled participating cruise 

ship lines and found represented vessels currently do not discharge to OCNMS waters for several 

reasons (John Hansen, former president NWCCA, personal communication). The opportunity to 

discharge in the sanctuary is limited by a short transit time (mean of 1.2 hours; Table 11), as well 

as a complex suite of voluntary and regulatory provisions in the NWCCA MOU, MARPOL, the 

CWA, and the VGP. In order to avoid discharges within the sanctuary, holding tank capacity of 

about 800 to 4,500 gallons for treated sewage and 5,000 to 18,000 gallons for graywater would 

be required. According to the EPA, cruise ship capacity to hold sewage (untreated or treated) 

ranges from 0.5 to 170 hours, with an average holding capacity of 62 hours (EPA 2008). 

According to the EPA, cruise vessel capacity to hold graywater varies significantly. According 

to responses to EPA‟s 2004 cruise ship survey, graywater holding capacity ranges from 5 to 90 

hours, with an average holding capacity of 56 hours (EPA 2008). Based on comparison of transit 

times through OCNMS with EPA‟s estimates, it is assumed all cruise ships currently operating in 

Washington state waters have sufficient holding tank capacity to retain sewage and graywater

while within the sanctuary. Therefore, avoidance of wastewater discharges during this small 

time window would not negatively impact vessel operations. 

As reviewed in section 6.1.3.1 and outlined in Table 17, there are several regulations and 

guidelines governing sewage (blackwater), graywater and other discharges to the sanctuary from 

large vessels, including cruise ships. Foreign flagged cruise ships from countries that have 

ratified MARPOL annex IV (probably the majority of the cruise ship fleet that transits the 

sanctuary) are subject to MARPOL Annex IV regulations. Even vessels not subject to 

MARPOL regulations (i.e., flagged from countries that have not ratified MARPOL Annex IV) 

are subject to CWA regulation. Washington State water quality regulations prohibit the 

discharge within state waters of treated effluents from any vessel that do not meet state water 

quality standards. The VGP addresses discharge of graywater, or sewage mixed with graywater, 

and numerous other effluents within 3 mi from shore. Members of the NWCCA are subject to 

the NWCCA MOU, a voluntary measure with measures that apply within the sanctuary. 

OCNMS is a defined marine jurisdiction identified on nautical charts with unique regulations 

governing discharges and other aspects of vessel operations. The complex suite of regulations 

and agreements governing wastewater discharges in OCNMS make it difficult for vessel 

operators to be sure where within the sanctuary it is appropriate to discharge various treated and 

untreated wastewater effluents. Moreover, the four national marine sanctuaries off California 

have regulations prohibiting discharge of wastewater from large vessels that apply to cruise 

ships. The discharge prohibition proposed for cruise ships provides regulatory clarity and 

eliminates ambiguity associated with various wastewater discharges at various distances from 

shore under various conditions. 

Because cruise ships in the sanctuary typically are in transit to other locations and would

already be spending the fuel and time necessary to traverse the sanctuary, no additional fuel 

costs are anticipated as a result of the proposed regulations. Furthermore, for vessel captains, 

regulatory consistency between national marine sanctuaries on the West Coast may be desirable 

as it reduces the complexity of operations that span multiple jurisdictions with diverse 

regulatory requirements and limitations (John Hansen, former president NWCCA, personal 

communication). In sum, restrictions on discharges from cruise ships under alternatives B and C 
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could be considered to have a less than significant effect on the human/socioeconomic setting. 

In addition, NOAA does not expect there to be any significant effect on employment, incomes, 

or housing due to the cruise ship discharge regulations proposed under alternatives B and C. As 

a result, NOAA expects less than significant, beneficial, direct, short term or long-term effects on 

the socioeconomics of the regulated community.

Table 17 Regulatory framework governing graywater and (sewage) blackwater discharges from vessels 

over 300 GT into OCNMS

Regulation or Agreement Waste Type Discharge Conditions

MARPOL Annex IV Comminuted and disinfected sewage 

using an approved system

 > 3 nmi from shore

MARPOL Annex IV Sewage stored in holding tanks 

(untreated and treated sewage)

 > 12 nmi from shore; and

 Discharged while underway

MARPOL Annex IV Treated sewage effluent discharged 

through an IMO approved sewage 

treatment plant (STP), also integrated 

system where the STP includes

 graywater input

 food processing input

 Allowed any distance from shore if the following 

conditions are met; 

 Effluent not to produce visible floating solids nor 

cause discoloration of surrounding water

Clean Water Act Untreated sewage  > 3 mi from shore

Clean Water Act Sewage treated by a USCG approved 

MSD

 Any distance from shore

Vessel General Permit Sewage  Not covered by VGP

Vessel General Permit Untreated or traditional MSD treated 

graywater, or graywater mixed with 

sewage

 >3 mi from shore 

Vessel General Permit AWTS treated graywater or graywater 

mixed with sewage

 Any distance from shore if effluent limits are 

achieved and documented through monitoring

Washington State Water 

Quality Standards (WQS) (per 

Chapter 90.48 RCW and 

Chapter 173-201A WAC)

Traditional MSD treated sewage  In State waters*

 Must meet marine WQS at point of discharge

Washington State Water 

Quality Standards (WQS) 

AWTS treated sewage and graywater  In State waters

 Only allowed outside 0.5 mile from shellfish beds

 Must meet terms outlined in NWCCA MOU

NWCCA MOU Untreated sewage  Outside of State waters

NWCCA MOU Residual Solids from Type II MSD or 

AWTS 

 > 12 nmi from shore

 Outside of State waters and OCNMS boundaries

NWCCA MOU Traditional MSD treated sewage  Outside of State waters

NWCCA MOU AWTS treated waste (blackwater and 

graywater)

 >1 mi from shore and >6 knots if certain 

requirements are met and effluent is continuously 

monitored; and

 Not within 0.5 miles from shellfish beds

*State waters include the Puget Sound and the Strait of Juan de Fuca south of the international boundary with 

Canada; and for off the west coast, the belt of seas measured from the line of ordinary low water along that portion of 

the coast which is in direct contact with open sea and the line marking the seaward limit of inland waters, and 

extending seaward a distance of three nautical miles.
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8.4.3 Actions with Adverse Effects to the Human/Socioeconomic Setting

There are some actions being considered under alternatives B and C potentially resulting in 

adverse effects to the human/socioeconomic setting, including:

 Reducing the OCNMS overflight regulation from 2,000 feet to 1,000 feet (alternative C)

 A regulatory ban on discharges from large vessels (alternative C)

 Evaluate options to make compliance with the Area-to-be-Avoided mandatory 

(alternative C)

 Regulatory ban on the discharge of invasive species (alternative C)

For purposes of this analysis, adverse effects to the human/socioeconomic setting are those 

negatively affecting the overall economy, business activity, employment, incomes, or housing 

for those populations adjacent to or dependent on the sanctuary. Adverse effects could result if 

these regulations caused the communities described in section 6 to:

 Experience reduced employment levels

 Experience decreased wages to cover potential increased costs of regulatory compliance

 Experience a decrease in business activity in or near coastal communities

 Incur increased operational costs by altering routes to avoid discharges in the sanctuary

The significance of any adverse socioeconomic effects must be carefully considered. There exist 

some administrative definitions of significance. Presidential Executive Order 12866 defines a 

significant impact for Federal Regulations as any impact of $100 million or more. When the 

impact of a Federal Regulation is expected to have impacts of $100 million or more, then the 

requirement is the Federal agency proposing the regulation must conduct a benefit-cost analysis 

of the regulation. None of the actions proposed under any of the three alternatives considered 

here would cause this level of socioeconomic impact.

Frequently, a threshold of $1 million is used to define the socioeconomic significance of an 

action. If the action causes an economic loss of $1 million or more then it is considered 

significant. If it causes an economic loss of less than $1 million then it is not considered 

significant. Within the context of this analysis, a $1 million threshold makes sense and is applied

when considering the effects of actions on large industries (e.g., the cruise ship industry). 

However, this threshold does not necessarily make sense when considering economic effects on 

the small rural communities adjacent to the sanctuary, which have high poverty and 

unemployment rates. An economic loss of less than $1 million dollars could be significant in 

these communities.

The National Marine Fisheries Service (NMFS) considers impacts of five percent or more of a 

fishing community‟s income or employment to be significant. Fishing communities are defined 

as Census Designated Places or cities depending directly or indirectly on the recreational and 

commercial fisheries for at least 20 percent of either their income or employment, or in which 

20 percent of the population living in the community is directly or indirectly dependent on the 

fisheries. When evaluating socioeconomic effects specifically to fishing communities, OCNMS 

has considered the NMFS significance standard of five percent or more of a fishing community‟s 

income or employment. For the purposes of this analysis, the communities directly adjacent to 
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the sanctuary are considered to be fishing communities. Neah Bay, La Push and Westport 

(which is not directly adjacent to the sanctuary but is a community close to the sanctuary) have 

been identified by NMFS as fishing communities (NMFS 2007). Taholah, WA is not identified 

in NMFS‟s Community Profiles for West Coast and Pacific Fisheries as a fishing community; 

however, for the purposes of this analysis, OCNMS considers Taholah to be a fishing community 

given the importance of fishing to the Quinault Indian Nation. 

8.4.3.1 Regulatory Reduction in Overflight Floor (alternative C only) – Effects to the 

Human/Socioeconomic Setting

A modification of the OCNMS overflight regulation to lower the floor from 2,000 feet to 1,000 

feet would provide regulatory consistency between national marine sanctuaries on the West 

Coast but simultaneously create an OCNMS regulation inconsistent with the FAA advisory for 

the same air space that applies to the national park and national wildlife refuges off the outer 

coast of Washington. ONMS believes a lower flight floor would not alter the number or type of 

planes flying over the sanctuary, but it could affect the socioeconomic setting of the sanctuary by 

increasing the noise detectable and visual impact to visitors on the shoreline adjacent to the 

sanctuary, much of which is designated wilderness within Olympic National Park. Federal 

wilderness lands are characterized as areas of undeveloped land retaining its primeval character 

and influence, without permanent improvements or human habitation. Designated wilderness is 

protected and managed so as to preserve its natural conditions, and where the imprint of man‟s 

work is substantially unnoticeable, and there are outstanding opportunities for solitude. The 

2,000 foot FAA advisory applying to national parks and wildlife refuges mitigates the visual and 

acoustic impact to wildlife as well as human visitors. Based on inconsistency between this 

proposed regulation and FAA advisory for the same area as well as its affect to the aesthetic 

value of the ONP wilderness shoreline, this alternative would have a less than significant, 

adverse, direct, and long-term effect on human/socioeconomic resources because potential 

confusion concerning overflight regulations and advisories may be introduced and the wildness 

aesthetic may be compromised. Because this alternative is unlikely to cause socioeconomic 

impacts to Olympic National Park, local communities or the aviation industry on the order of 

$1 million or greater, the socioeconomic effects are considered less than significant.

8.4.3.2 Changes to Vessel Discharge Regulation (alternative C) – Effects to the 

Human/Socioeconomic Setting

Alternative A (no action) does not propose additional discharge regulations on vessels in the 

sanctuary. As a result, no significant adverse short-term or long-term direct or indirect impacts

on the human/socioeconomic setting are expected to occur from alternative A. Alternative B 

does propose a ban on cruise ship discharges, but this action is expected to have a beneficial, 

long-term, direct effect on the human/socioeconomic setting and thus is not discussed within the 

context of adverse effects.

The large commercial vessel discharge regulation proposed under alternative C has potential to 

cause some adverse effects to the human/socioeconomic resources. Alternative C proposes an 

expansion of discharge regulations to include a ban on all discharges from large vessels (over 

300 gross tons), with the exception of some clean discharges required for vessel operation and an 

exception for vessels not able to comply based on their existing design, i.e., sewage or graywater 

holding capacity. Affected vessels 300 gross tons and above could include public vessels, 

commercial vessels, passenger vessels (other than cruise ships), fishing vessels and tank vessels. 
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These vessels operate throughout the OCNMS and conduct a wide range of the activities 

described in section 6 (Human/Socioeconomic Setting). 

Some large vessel operators could incur additional costs, resulting from changes in operating 

procedures, required for compliance with OCNMS vessel discharge regulations under alternative 

C in order to continue their activities in the sanctuary. These effects would be applicable to:

 Large commercial vessels using the sanctuary for transit

 Commercial fishing vessels using the sanctuary for transit or for fishing operations 

 Defense-related vessels using the sanctuary for transit or for training

 Research-related vessels using the sanctuary for transit or for research

Impacts to U. S. Navy vessels should be negligible. The Navy‟s current policy is “While transiting 

National Marine Sanctuaries, ships and submarines shall avoid any adverse impacts on Sanctuary 

resources and qualities. Ships and submarines shall minimize, to the maximum extent practicable, 

any solid waste, sewage, or bilge water discharges” (Section 22-922-2.2.10 Prohibited Discharge 

Zones for U.S. Navy Shipboard Wastes, of OPNAVINST 5090.1C, U.S. Navy 2007). Moreover, 

OCNMS regulations include an exception to the discharge prohibition for identified military 

activities performed by the Department of Defense in operations areas W-237A, W-237B, and 

MOAs Olympic A and B that cover the majority of OCNMS (Figure 10). 

Alternative C would have a minimal effect on the operation of large commercial vessels 

transiting OCNMS en route to and from Puget Sound and Canadian Ports with respect to sewage 

and graywater management. Most large commercial vessels traversing the sanctuary are 

expected to have adequate sewage and graywater holding capacity to avoid discharging during 

the typically short 1.2 to 3.6 hour (Table 11) transit of the OCNMS. Most large commercial 

vessels have relatively small crews (e.g., 4 - 15 people), and thus do not generate sewage or 

graywater in volumes comparable to cruise ships. In order to avoid sewage discharges within the 

sanctuary, an estimated holding tank capacity of between 5 and 30 gallons would be required; 

and most large vessels have this capacity. Likewise the volume of graywater generated and 

potentially discharged in the sanctuary is relatively small. Although there is significant variation 

among vessels, most large commercial vessels have sufficient storage capacity for graywater to 

allow vessel operations for 20 to 48 hours without discharge (Pruitt 2004). Although sewage and 

graywater holding capacity likely exists on most ships, operational procedures for securing 

overboard discharges would need to be developed and implemented. 

For all vessels, no additional costs related to fuel and transit time are expected to occur with 

implementation of alternative C. Since the practice of calling on Puget Sound and Canadian 

ports is expected to continue compliant with the CVTS and ATBA, with or without 

implementation of alternative C, impacts to vessels currently complying with the ATBA (vessels 

>1,600 GT) would be negligible. Rather, alternative C would simply prompt large commercial 

vessels to hold their sewage until they are outside the sanctuary boundary. 

Vessels operating in the OCNMS for substantial lengths of time are potentially more affected by 

the provisions of Alternative C than large commercial vessels. Vessels such as public research

vessels and commercial fishing vessels may remain in the sanctuary to perform their allowed 

functions. These vessels may not have adequate capacity to retain sewage and graywater while 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

within OCNMS. However, under Alternative C, exceptions to this rule are allowed based on a 

vessel‟s existing design and holding tank capacity. As an example the NOAA Ship McArthur II, 

a 224 foot 1,914 GT research vessel, occasionally conducts research cruises within OCNMS. 

The McArthur II has a combined sewage and graywater holding tank of 4,000 gallons, which for 

a typical crew of 37 provides a wastewater holding capacity of approximately 2 days. Without 

the exception for vessels not able to comply based on their existing design, the McArthur II

would be required to break from research operations every other day to transit to an area where 

discharge of sewage and graywater were legal. With this exception, under this alternative, there 

would be an allowance for the vessel‟s existing design and holding tank capacity.

Some commercial fishing vessels operating in OCNMS are greater than 300 GRT and would 

therefore be regulated under Alternative C. The NOAA Vessel Monitoring System (VMS) data 

analyzed by OCNMS, which includes participating commercial fishing vessels, does not include 

the tonnage of the vessel, so the number of commercial fishing vessels 300 GT or above (those 

affected by alternative C) is unknown. However, the CVTS data set does include tonnage. Of

the fishing vessels documented in CVTS data, 23% were 300 GT or above (Table 11; see 

Appendix K for a description of VMS and CVTS data.). For commercial fishing vessels, time 

spent in the sanctuary is a combination of transit and fishing time. Table 11 estimates the 

average duration of commercial fishing vessel transits (vessels not actively fishing) ranges from 

2.6 to 3.2 hours. Holding tank capacity of about 3 to 14 gallons for sewage and 17 to 56 gallons 

for graywater would be required in order to avoid discharges while in the sanctuary during 

transits. However, fishing vessels actively fishing could spend a significantly longer period of 

time in the sanctuary. Based on VMS data, there were 153 fishing trips, or approximately 5% of 

fishing trips in 2009, exceeding two days. Based on this information it is reasonable to conclude

there are fishing vessels greater than 300 GT in the sanctuary for a period of time that would 

exceed their holding tank capacity. Again, the exemption for existing vessel design would 

mitigate the impact of this alternative.

While the exemption for existing vessel design greatly mitigates the financial impact from this 

regulation, there would be some minimal costs involved in complying with the regulation. Large 

commercial vessel operators, in particular, would need to establish procedures for securing 

overboard sewage and graywater discharge. These costs would vary based on vessel design and 

operations. The adverse effects of this alternative would be less than significant, direct and longterm. The effects are considered less than significant because, given the exception for existing 

vessel design and the existing capacity of most vessels to adhere to the proposed regulation 

without major modifications to their structures or routes, it is unlikely this regulatory change 

would cause a loss of $1 million or more to any industry.

8.4.3.3 Area-to-be-Avoided – Effects to the Human/Socioeconomic Setting

Currently, the Olympic Coast Area to be Avoided (ATBA) is an International Maritime 

Organization (IMO) voluntary vessel routing measure for vessels 1,600 gross tons and above. 

The ATBA has been in place since 1994, and its compliance rate has been high, estimated to be 

98.9% in 2009 (WDE 2010). To maintain the high compliance rate, OCNMS works with the 

USCG to notify non-compliant vessels with a formal letter requesting they adhere to the ATBA 

in the future. 
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

Under alternative C, OCNMS would work with its partners to evaluate options to make 

compliance with the ATBA mandatory. In order to understand the extent and potential 

significance of changing the voluntary nature of the ATBA, OCNMS evaluated ATBA 

compliance rates and identified the population of vessels not voluntarily complying with the 

ATBA. OCNMS further evaluated responses from the ATBA Monitoring and Outreach program 

to evaluate response from industry on reasons for non-compliance.

The transits of vessels for which the ATBA applies off the Olympic Coast in 2009 are 

summarized in Table 15. In 2009, 8,849 transits (vessels for which the ATBA applies) were 

tracked by Cooperative Vessel Traffic Service (CVTS) monitoring. Of these transits, 6,128 

entered OCNMS (Figure 11), with a total of 68 transiting within the ATBA (Figure 12). In 2009 

the ATBA voluntary compliance rate was estimated at near 99%. 

To better understand the reasons for non-compliance for these 68 transits ONMS reviewed 

responses from these vessels (see 8.2.1.4). The sanctuary has concluded changing the ATBA 

provisions from voluntary to mandatory would have a minimal impact in the behavior of 

shipping in the sanctuary. There would be some increased costs to both the government and the 

maritime industry in implementing a mandatory ATBA provision. The effect of this alternative 

would be less than significant, adverse and long-term. The effect is expected to be less than 

significant because, given the nearly perfect compliance rate with the ATBA that already exists,

there is no indication this change to the ATBA would lead to a loss of $1 million or more to the 

shipping industry.

8.4.3.4 Regulatory Ban on Invasive Species Discharge – Effects to the 

Human/Socioeconomic Setting

Alternative C would include a ban on the discharge of invasive species in the sanctuary. It is 

assumed this action could have some adverse effect on the human setting because it would 

restrict people from farming invasive species (e.g., Atlantic salmon) in the sanctuary, although 

ONMS could consider granting a permit for an aquaculture project on a case-by-case basis. An 

OCNMS permit would be required for any aquaculture project in the sanctuary because such a 

project would trigger OCNMS‟ discharge or seafloor disturbance regulations. Therefore, 

potential impacts of invasive species would be an additional consideration for OCNMS 

permitting if such a project were proposed. It is assumed the adverse socioeconomic effect of 

this regulation would be less than significant because ONMS has never received an application 

from any entity seeking to farm an invasive species in OCNMS and knows of no plans under 

development at this time. Thus, ONMS, through this regulatory change, would not expect to 

cause any significant (>$1 million) economic losses to the aquaculture industry. It is also

important to note a ban on discharging invasive species in the sanctuary would not be equivalent 

to a ban on aquaculture in the sanctuary. Farming operations involving native species would be 

considered but, as noted above, likely would require an OCNMS permit. 

8.4.4 Summary of Effects to Human/Socioeconomic Setting

In general, the majority of actions being considered under alternatives A, B and C would have 

some beneficial, less than significant effects on the human/socioeconomic setting in the 

sanctuary. There is not a substantial difference in the beneficial effects expected from the three 

alternatives. 
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The actions under both alternatives A and B are expected to have solely beneficial effects on the 

human/socioeconomic setting. The actions under alternative C are expected to have primarily 

beneficial effects on the human/socioeconomic setting, but also may have some less than 

significant, adverse effects. 

The beneficial effects of all three alternatives are considered less than significant because, while 

the actions under these alternatives are critical to achieving OCNMS‟ goals and objectives, they 

are relatively small in scale and are not expected, to cause a large and measurable improvement 

to the socioeconomic health of local communities over the life of the management plan (five to 

ten years). That is not to say revising the OCNMS management plan will not contribute

positively to local and regional socioeconomic improvements by promoting tourism on the 

Olympic Peninsula, providing resources to local school systems for educational programs etc. 

Regarding adverse effects to human/socioeconomic setting, the additional actions being 

considered under alternative C would have a less than significant adverse, direct, short and longterm effects on the socioeconomics of local communities. These effects could include minor 

increases in operating costs or foregone economic opportunities. No significant macroeconomic 

or fiscal impacts are expected. It is important to note, while significant effects on local 

economies are not expected as the result of any of the three management plan alternatives, that 

does not necessarily mean there would or wouldn‟t be significant effects on certain individuals or 

groups. Certainly if a person were among those who are impacted it could feel significant to that 

person. OCNMS has no basis for judging significance in this context. This analysis simply

provides OCNMS‟ best estimates of the extent of potential effects on communities overall.
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

8.5 CUMULATIVE EFFECTS

The National Environmental Policy Act and the White House Council on Environmental Quality 

(CEQ) require federal agencies consider the cumulative environmental effects of the action(s)

they propose. The cumulative effect of the proposed action is the incremental environmental 

effect the proposed action has when added to other past, present and future actions in the affected 

environment. Cumulative effects are critical to explore because it is often the combined effect of 

many actions in one area or region that causes the most significant adverse effects. 

Analyzing cumulative effects and assessing their significance can be challenging. OCNMS 

considers cumulative effects to be significant if they exceed the capacity of a resource 

(socioeconomic, biological, physical, historic and/or cultural) to sustain itself and remain 

productive. In order to analyze cumulative effects, OCNMS followed informal CEQ guidelines 

as documented in Considering Cumulative Effects Under the National Environmental Policy Act

(CEQ 1997). In these guidelines, CEQ presents an 11-step process for reviewing and assessing 

cumulative impacts.

Actions identified under alternatives A, B and C as causing any beneficial or adverse effects to 

resources were reviewed to identify potential cumulative issues. The geographic scope and time 

frame for the cumulative effects analysis are the same as for the management plan review, i.e., 

the existing boundaries of OCNMS and a 5-10 year time frame. In conducting this analysis 

OCNMS utilized the findings from the 2008 Condition Report as a baseline (ONMS 2008).

The analysis of cumulative effects considers the present effects of past actions to the extent they 

are relevant and useful in analyzing whether the reasonably foreseeable effects of the Proposed 

Action and future projects would collectively result in a significant effect on the environment. 

Process for Reviewing and Assessing Cumulative Impacts (CEQ 1997)

Step 1 – Identify the potentially significant cumulative effects issues associated with the 

proposed action and define the assessment goals.

Step 2 – Establish the geographic scope for the analysis

Step 3 – Establish the time frame for the analysis

Step 4 – Identify other actions affecting the resources, ecosystems, and human 

communities of concern

Step 5 – Characterize the resources described in the affected environment in terms of their 

response to change and capacity to withstand stresses.

Step 6 – Characterize the stresses affecting these resources and their relation to regulatory 

thresholds

Step 7 – Define a baseline condition for the resources

Step 8 – Identify the important cause-and-effect relationships between human activities and 

the resources

Step 9 – Determine the magnitude and significance of cumulative effects

Step 10 – Modify or add alternatives to avoid, minimize or mitigate significant cumulative 

effects.

Step 11 – Monitor the cumulative effects of the selected alternative and adapt management.
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ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

The following projects include only those with some potential to contribute to the cumulative 

effects:

 Seafloor disturbance 

 Noise pollution

 Vessel operations

 Trampling

 Invasive species regulations 

 Vessel discharge regulations

 Climate change

 Marine resource protection

8.5.1 Cumulative Effects of Seafloor Disturbance

There are two primary types of OCNMS operations disturbing the seafloor - anchoring of 

research moorings and bottom grab samples. Analysis of these actions has found them to be less 

than significant, adverse, direct and short-term to the biological, physical and historic and 

cultural setting of the sanctuary. Other non-OCNMS actions within the boundaries of the 

sanctuary that also disturb the seafloor and which contribute to the cumulative impacts to these 

resources include the installation of cables, bottom contact fishing gear, the Quillayute River 

Harbor Project, the abandonment of sunken vessels, some Naval operations, and the conduct of 

non-OCNMS research activities.

The 2008 Condition Report concluded selected habitat loss or alteration has taken place from 

human activities, and the most significant impact likely has resulted from bottom contact 

fisheries conducted for years over broad areas (ONMS 2008). The area of the seafloor disturbed 

by OCNMS actions is miniscule compared other activities. Therefore, the actions of OCNMS do 

not significantly contribute to the cumulative effects of seafloor disturbance.

8.5.2 Cumulative Effects of Noise Pollution

OCNMS operations under all three alternatives would contribute to noise in the sanctuary 

include vessel and survey operations. However, OCNMS activities are small in scope and 

intensity compared with existing traffic. Additional sources of noise pollution in the sanctuary 

include commercial shipping and military operations. The primary source of low-frequency 

ocean noise is commercial shipping (NRC 2003). In 2009 there were approximately 7,000 

transits of large vessels (over 300 GT) in the sanctuary (Table 11). An additional source of noise 

pollution in the sanctuary is military operations, for which there are exceptions to OCNMS 

regulations provided in 15 CFR 922.152(d). Both the Northwest Training Range Complex and 

the Quinault Underwater Test Range overlap with the boundaries of OCNMS. Both of these 

military operating areas have been subject to recent NEPA analysis and MMPA permitting

requirements. While the cumulative effects of noise pollution within the sanctuary have not been

documented, ONMS believes its contribution to these the cumulative effect would be less than 

significant, adverse, direct and short-term under all three alternatives, due to the separation in 

time and space from these vessel operations and the large areas of the sanctuary excluding large 

vessel transits, e.g., the ATBA.
230

ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

8.5.3 Cumulative Effects of Vessel Operations

In addition to noise pollution, the operation of vessels within the sanctuary can have an effect on 

physical and biological setting by providing a potential source of water pollution. Additional 

effects can occur through harassment of wildlife and/or ship strikes. Current level of OCNMS 

operations is at approximately 12.5 vessel days (300 hours of operations). This is out of an 

approximate total of 5,000 vessel days occurring annually in the sanctuary (Table 6). The nature 

of these operations is generally disbursed with some concentrations occurring at harbor 

entrances, popular fishing grounds, and in vessel traffic lanes. The 2008 Condition Report 

concluded water quality in the sanctuary is in good condition (ONMS 2008). Therefore, the 

cumulative effects of OCNMS vessel operations under all three alternatives would be less than 

significant, adverse, direct and short-term.

8.5.4 Cumulative Effects of Trampling

Actions occurring in the intertidal zone with potential to have an adverse effect through 

trampling include: 

 Beach and intertidal educational and interpretive programs

 Intertidal surveys

 Marine debris removal projects

 Encouraging visitation to beaches and intertidal areas

Other actions contributing to this type of impact include Olympic National Park and school 

group interpretive activities, and impacts from the general public‟s visitation to intertidal areas. 

The 2008 Condition Report found that while selected habitat loss or alteration has taken place 

from human activities, these impacts are unlikely to cause substantial or persistent degradation to 

living resources (ONMS 2008). Therefore, the cumulative effects of intertidal activities under 

all three alternatives would be less than significant, adverse, direct and short-term.

8.5.5 Cumulative Effects of Invasive Species Regulations

Alternative C includes a new regulation, which would ban the discharge of invasive species in 

the sanctuary. Other actions impacting the cumulative effect of this regulation include current 

state of Washington regulations restricting the introduction of invasive species in state waters. 

Because the addition of an OCNMS invasive species discharge ban 1) would be largely 

redundant with state of Washington regulations and 2) would likely not add any significant 

additional protections for resources in the sanctuary, the cumulative effects of the invasive 

species regulation would be beneficial, indirect, long-term and less than significant.

8.5.6 Cumulative Effects of Vessel Discharges

Alternatives B and C both contain regulations which would prohibit certain discharges from 

different classes of vessels in order to support efforts to maintain water quality in the sanctuary. 

Other actions effecting water quality in the sanctuary include an existing Washington State and 

Northwest CruiseShip Association Memorandum of Understanding (MOU) that restricts cruise 

ship discharges in state waters, state of Washington ballast water regulations that restrict vessel 
231

ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

discharges in and adjacent to state waters, the IMO Area-to-be-Avoided, and federal (EPA) 

water quality regulations (e.g., Clean Water Act). 

The 2008 Condition Report found water quality in the sanctuary to be in “good” condition

(ONMS 2008). Furthermore, preceding analyses of potential OCNMS vessel discharge 

regulation changes indicate these potential regulatory changes would have only a small added 

benefit to water quality in the sanctuary because existing regulations (state, federal and IMO) 

already provide substantial protection of water quality in most of the sanctuary. The cumulative 

effect of potential changes to OCNMS vessel discharge regulations in conjunction with existing 

state and federal water quality protection regulations would be beneficial, indirect, long-term and 

less than significant. 

8.5.7 Cumulative Effects of Climate Change

Climate change is, by nature, a cumulative effects issue. No single point source or event has 

caused climate change. Rather, the changing climate is cumulatively affected by many actions 

all over the globe. The United States government has identified climate change as a significant 

problem of national and international concern. The White House Council on Environmental 

Quality is currently developing guidelines federal agencies can use to address the issue of 

climate change in the NEPA process. Through the management plan review process, ONMS has 

addressed the issue of climate change in detail by developing a Climate Change Action Plan and 

Sanctuary Operations Plan to be implemented under alternatives B and C. Both of these action 

plans discuss ways in which ONMS would reduce its carbon footprint and work with local 

communities in the sanctuary region to understand and address the issue of climate change.

The burning of fossil fuels contributes to the build-up of greenhouse gases in the atmosphere. 

The build-up of greenhouse gases in the environment in turn influences climate. Alternatives A, 

B and C contain actions requiring the burning of fossil fuels to support the operation of sanctuary

vessels and vehicles. Additionally, there is a significant volume of marine shipping and vessel 

operations occurring in the sanctuary. Insufficient data exist to characterize the specific effect or 

contribution of fossil fuel burning in the sanctuary region on or to global climate change. 

However, given the small scale of OCNMS activities involving fossil fuel burning, it is unlikely 

OCNMS greenhouse gas contributions under alternatives A, B or C would cause a significant 

change in the cumulative effect of fossil fuel burning in the sanctuary region. Under all three 

alternatives, ONMS would continue to maintain a small staff, a small fleet of vehicles and 

vessels, and would engage in no commercial or industrial-scale fossil fuel burning activities. 

Thus, the cumulative effects of all three alternatives on climate change are assumed to be 

adverse, but less than significant.

8.5.8 Cumulative Effects of Marine Resource Protection

Alternatives A, B and C consider actions providing protection for marine resources in the 

sanctuary. The National Park Service and the U.S. Fish and Wildlife Service also provide 

protections for marine resources in and adjacent to the sanctuary through the management of 

Olympic National Park and the Washington Maritime Wildlife Refuge Complex. Thus, there is a 

less than significant, beneficial, cumulative effect of having multiple federal protection structures 

(park, refuge and sanctuary) for marine resources in the sanctuary. This cumulative effect under 

all three alternatives is assumed to be less than significant because the combined 
232

ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

park/refuge/sanctuary area represents a relatively small area of the Pacific Ocean in which these 

types of protections for marine resources are provided.

8.5.9 Actions for Future Analysis

Many of the actions and strategies under all three alternatives provide broad management 

direction. Where actions are specific and adequately defined, the environmental consequences 

have been analyzed. Conversely, actions that are broad and general in nature would be analyzed 

in future environmental and cultural compliance documents, once sufficiently specific actions are 

proposed and defined. Examples of actions that may be analyzed in the future include: 

 Construction of visitor centers, storage facilities, staff offices, interpretive signage and 

vessels

 Potential maritime archeological investigations

 Potential discovery of maritime archeological sites requiring development of preservation 

and protection plans

 Potential submerged marine debris removal projects (e.g., removing buried crab pots, 

abandoned vessels, etc.)

 Potential OCNMS permit applications to conduct a variety of human development 

activities in the sanctuary (e.g., fiber optic cable installations, alternative energy projects 

etc.)

Alternatives B and C both provide guidance for future expansion of OCNMS programs. Specific 

details for how these programs may expand would not be developed until the resources to 

support such expansions are available. At that time, appropriate environmental and cultural 

review and compliance documentation would be developed in accordance with NEPA, NHPA, 

NOAA guidelines, as well as Endangered Species Act (ESA), CWA, and other federal laws. 

Additionally, ONMS cannot anticipate the nature of permit applications it may receive to 

conduct prohibited activities in the sanctuary. Permit applications must be analyzed on a caseby-case basis, and an appropriate level of environmental and cultural compliance documentation 

would be determined on a case-by-case basis.
233

ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

8.6 SUMMARY OF EFFECTS

Effects to the physical, biological, historical/cultural, and human/socioeconomic settings were 

analyzed for each of the three alternatives being considered (Table 18). Effects were classified 

as beneficial or adverse, direct or indirect, short-term or long-term and significant or less than 

significant (terms all of which are defined in the introduction to section 8.0). The types of 

actions analyzed (Table 13) included, but were not limited to:

 Routine OCNMS resource protection, research, education, outreach, visitor services, 

maritime heritage, administration activities

 Potential changes to OCNMS regulations (related to vessel discharges, invasive species 

etc.)

 OCNMS vessel operations 

 Research and monitoring activities causing seafloor and wildlife disturbance and 

disturbance to the intertidal zone

 Continuation and potential expansion of the Area-to-be-Avoided

Table 18 Comparison of effects of the three alternatives on physical, biological, historic/cultural and 

socioeconomic resources

Setting Effects of Alternative A Effects of Alternative B Effects of Alternative C

Physical Less than significant, adverse 

and beneficial 

Less than significant, adverse 

and beneficial

Less than significant, adverse 

and beneficial

Biological Less than significant, adverse 

and beneficial

Less than significant, adverse 

and beneficial

Less than significant, adverse 

and beneficial

Historic/Dultural Less than significant, adverse 

and beneficial 

Less than significant, adverse 

and beneficial 

Less than significant, adverse 

and beneficial 

Human/Socioeconomic Less than significant, adverse 

and beneficial

Less than significant, adverse 

and beneficial 

Less than significant, adverse 

and beneficial 

Cumulative Less than significant, adverse 

and beneficial 

Less than significant, adverse 

and beneficial 

Less than significant, adverse 

and beneficial 

Additionally, the cumulative effects of the actions proposed under all three alternatives were 

analyzed within the context of other federal and non-federal activities occurring in the sanctuary. 

In all cases, the effects of all three alternatives were found to be less than significant (Table 18).

As the environmental consequences analysis demonstrates, revision of OCNMS‟ management 

plan (under all three alternatives) would have an overall beneficial effect on resources in the 

sanctuary (biological, physical, historic/cultural and socioeconomic). Because the management 

plan is a broad, guidance document, these beneficial effects would in many cases be indirect, 

occurring as ONMS takes actions to improve 1) public understanding of marine conservation 

issues, 2) scientific understanding of sanctuary ecosystems and historic and cultural resources, 

3) marine stewardship and maritime heritage programs, 4) OCNMS regulations in order to 

reduce potential stressors on marine resources (e.g., vessel discharges, oil spills and potential 

invasive species introductions). These effects would be less than significant because they alone 

are not likely to result in a substantial, measurable improvement of resource health over the 

relatively short life of the management plan (five to ten years). 
234

ENVIRONMENTAL CONSEQUENCES OF ALTERNATIVES

Measurable changes in the health of resources in the sanctuary will likely occur over a longer 

period of time, and as the result of incremental changes in human behavior that ONMS hopes to 

influence through the continuation and development of its research, resource protection, 

education, outreach, visitor and maritime heritage programs. To say these beneficial effects are 

less than significant is not to say they are not critical to OCNMS‟ mission or to resource 

protection efforts in the sanctuary. Revising the management plan, particularly as discussed 

under the preferred alternative B, would provide a strategic and detailed path forward for 

OCNMS and its partners to achieve more effective management and protection of resources in 

the sanctuary. However, within the context of NEPA, these beneficial effects do not meet the 

criteria of “significant”.

In addition to these beneficial effects, some actions proposed under all three alternatives would 

cause direct and indirect adverse effects on resources. These adverse effects include, for 

example, disturbance to wildlife in order to monitor and understand the health of species in the 

sanctuary, disturbance to the seafloor in order to install water quality monitoring buoys. In all 

cases, adverse effects were found to be less than significant because ONMS conducts these 

activities on a small scale, in a manner that substantially minimizes impacts to resources, and in a 

manner minimizes costs for sanctuary users. 

Cumulative effects of actions under all three alternatives were also found to be less than 

significant. For the most part, this is because the effects of OCNMS actions (beneficial and 

adverse) are small in scale. Thus, the addition of these effects to those of other similar activities 

occurring in the sanctuary would not significantly alter the cumulative effects of these activities 

overall. In some cases, there was little information available to assess the effects of other 

entities‟ activities in the sanctuary. In such cases, the information available suggested the 

cumulative effects would be less than significant. Should additional information about these 

activities become available in the future, it would be incorporated into future OCNMS NEPA 

cumulative effects analyses.
235

PERSONS AND AGENCIES CONTACTED

9 PERSONS AND AGENCIES CONTACTED

This list includes all people and agencies that assisted OCNMS in developing the action plans in 

the Final Management Plan or in reviewing aspects of the environmental effects analysis.

Olympic Coast National Marine 

Sanctuary Advisory Council

Bob Boekelheide 

Bob Bohlman (former Vice Chair)

Chip Boothe (Chair)

Captain Scott Bornemann

Ginny Broadhurst

Diane Butorac

John Calambokidis

Al Carter

Mike Doherty

Kevin Duffy

Steve Fradkin

Doug Fricke

Caroline Gibson

Joe Gilbertson

Garth Griffin

Mike Gurling

Karen Gustin

Jennifer Hagen

George Hart

Frank Holmes

Dave Hudson

Phil Johnson

Ed Johnstone

Steve Joner

Joel Kawahara

Jody Kennedy 

Dr. Terrie Klinger

Fayette Krause 

Katie Krueger

Ellen Matheny (Secretary)

John Miller

Mel Moon, Jr.

Roy Morris

Corey Niles

Meri Parker

Captain Scott Pollock

Rebecca Post

David Price

David Roberts

Kevin Ryan

Dana Sarff

Joe Schumacker

Brady Scott (Vice Chair)

Teresa Scott

Fan Tsao

Lee Whitford

Gene Woodwick

Olympic Coast Intergovernmental Policy 

Council

Citizen

Nancy Messmer

Coastal Maritime Archeological Resources

Carl Harrington

Ecotrust

Charles Steinbeck

Feiro Marine Life Center

Betsy Wharton

Deborah Moriarty

David Morris

Friends of the Earth

Marcie Keever 

Fred Felleman

Forks High School

John Hunter

Foss Maritime

Bruce Reed
236

PERSONS AND AGENCIES CONTACTED

Grays Harbor College

Lorena Marchant

Sarah Shaw

Hoh Tribe

Warren Scarlett

Joe Gilbertson

David Hudson

Hoh River Residents’ Association

John Richmond

Holland America Line

Jon Turvey

Makah Tribe

Micah McCarty

Steve Joner

Sue Wolf

Dana Sarff

Greg Arnold

Chad Bowechop

Janine Bowechop

Meri Parker

Marine Exchange of Puget Sound

Bob Bohlman

John Veentjer

Marine Spill Response Corporation

John Bowles

Craig Cornell

NOAA Office of Response and 

Restoration

Doug Helton

National Marine Fisheries Service, 

Northwest Region

Kevin Duffy

Garth Griffin

Frank Lockhart

Brent Norberg

Yvonne deReynier

Natural Resources Consultants, Inc.

Jim Riedel

Tim Gallo

Jeff June

North Pacific Coast Marine Resources 

Committee

Rich Osbourne

North Pacific Fishing Vessel Owners’ 

Association

Leslie Hughes

Northwest Fisheries Science Center

Jason Cope

Phil Levin

Vera Trainer

North West and Canada Cruise

Association

Donna Spalding

John Hansen

Northwest Indian Fisheries Commission

Rob Jones

Eric Wilkins

Craig Bowhay

Debbie Preston

Olympic Coast Alliance

John Woolley

Oceana

Ben Enticknap

Ocean Shores Interpretive Center

Gene Woodwick

Ocean Shores School District

Karen Rasmussen

Beth Rockey
237

PERSONS AND AGENCIES CONTACTED

Olympic National Park

Steve Fradkin

Judy Lively

Dean Butterworth

Dave Conca

Paul Gleeson

Colin Smith

Kathy Steichen

Karen Gustin

Jacilee Wray

Olympic Park Institute

Kent Chapple

Shannon Walz

Randall Walz

Pacific Fishery Management Council

Pacific Merchant Shipping

Mike Moore

Port Angeles School District

Dan Lieberman

Quileute Tribe

Jennifer Hagen

Katie Krueger

Mel Moon

Chris Morganroth III

Quinault Indian Nation

Tom Gibbons

Ed Johnstone

Joe Schumacker

Reef Environmental Education 

Foundation

David Jennings

Seattle Aquarium

Karen Matsumoto

Surfrider Foundation

Jody Kennedy

Shannon Serrano

The Nature Conservancy

Jacques White

Tombolo Institute

Gary Greene

U.S. Coast Guard

Scott Bornemann

Scott Knutsen

U.S. Fish and Wildlife Service

Deanna Lynch

Sue Thomas

Kevin Ryan

U.S. Geological Survey

Sam Johnson

University of Washington

Dr. Barbara Hickey

Dr. Jan Newton

Dr. Julia Parrish

Washington Department of Fish and 

Wildlife

Greg Bargmann

Michele Culver

Dan Doty

Steve Jeffries

Allen Pleus

Heather Reed

Washington Department of Ecology

Chip Boothe

Diane Butorac

Jennifer Hennessey

Amy Jankowiac

Rebecca Post

Spencer Reeder

Washington State Historic Preservation 

Office

Rob Whitlam
238

PERSONS AND AGENCIES CONTACTED

Washington State Maritime Cooperative

Tom Callahan

Washington State Oil Spill Advisory 

Council

Jerry Joyce

Washington State University

Katherine Baril

Westport Historical Seaport

Les Bolton

Wright Brothers Aviation

Jeff Wells

Western Washington University

Nancy Bluestein-Johnson
239

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APPENDIX A – TERMS OF DESIGNATION

ABOUT THIS DOCUMENT

On May 11, 1994 the National Oceanic and Atmospheric Administration (NOAA) published the 

final Olympic Coast National Marine Sanctuary Regulations (59 FR 24586). This official 

government document also served as the notice of the Sanctuary‟s designation, the culmination 

of long and involved public process. The following excerpt from the complete documents is the 

“Designation Document”. You find a complete copy of the original 1994 document at 

http://sanctuaries.noaa.gov/management/fr/59_fr_24586.pdf or http://olympiccoast.noaa.gov.

Designation Document for the Olympic Coast National Marine Sanctuary

Under the authority of Title III of the National Marine Sanctuaries Act of 1972, as amended (the 

''Act''), 16 U.S.C. 1431 et seq., the waters off the Olympic Coast of Washington State including 

the U.S. portion of the Strait of Juan de Fuca west of Koitlah Point, and the submerged lands 

thereunder, as described in Article II, are hereby designated as the Olympic Coast National 

Marine Sanctuary for the purposes of protecting and managing the conservation, ecological, 

recreational, research, educational, historical and aesthetic resources and qualities of the area.

Article I. Effect of Designation

The Act authorizes the issuance of such final regulations as are necessary and reasonable to 

implement the designation, including managing and protecting the conservation, recreational, 

ecological, historical, research, educational, and aesthetic resources and qualities of the Olympic

Coast National Marine Sanctuary. Section 1 of Article IV of this Designation Document lists 

activities that either will be regulated on the effective date of designation or may have to be 

regulated at some later date in order to protect Sanctuary resources and qualities. Listing does not 

necessarily mean that a type of activity will be regulated; however, if an activity is not listed, it 

may not be regulated, except on an emergency basis, unless Section 1 of Article IV is amended 

to include the type of activity by the same procedures by which the original designation was 

made.

Article II. Description of the Sanctuary Area

The Olympic Coast National Marine Sanctuary boundary encompasses approximately 2500 

square nautical miles (approximately 8577 sq. kilometers) of coastal and ocean waters, and the 

submerged lands thereunder, off the central and northern coast of the State of Washington. The 

Sanctuary boundary extends from Koitlah Point due north to the United States/Canada 

international boundary seaward to the 100 fathom isobath. The seaward boundary of the 

Sanctuary approximates the 100 fathom isobath in a southerly direction from the U.S./Canada 

international boundary to a point due west of the Copalis River, cutting across the heads of 

Nitnat, Juan de Fuca, and Quinault Canyons.

The shoreward boundary of the Sanctuary is the mean lower low water line when adjacent to 

Indian reservations and State and county lands. When adjacent to Federally managed lands, the 
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coastal boundary extends to the mean higher high water line. The coastal boundary cuts across 

the mouths of all rivers and streams. The precise boundary of the Sanctuary is set forth in 

Appendix A of this Designation Document.

Article III. Characteristics of the Sanctuary Area That Give It Particular Value

The Sanctuary is a highly productive, nearly pristine ocean and coastal environment that is 

important to the continued survival of several ecologically and commercially important species 

of fish, seabirds, and marine mammals. Its rugged and undeveloped coastline makes the region 

one of the more dramatic natural wonders of the coastal United States, paralleling the majestic 

splendor of such terrestrial counterparts as Yosemite National Park and the Grand Tetons. The 

region's high biological productivity is fueled by seasonal enhanced upwelling along the edge of 

the continental shelf, especially at submarine canyons, during periods of high solar radiation.

The diversity of habitats that make up the Sanctuary support a great variety of biological 

communities. This unusually large range of habitat types include offshore islands and rocks;

some of the most diverse kelp beds in the world; intertidal pools; erosional features such as rocky 

headlands, seastacks, and arches; interspersed exposed beaches and protected bays; submarine 

canyons and ridges; the continental shelf, including a broad shallow plateau extending from the 

mouth of the Juan de Fuca canyon; and continental slope environments. The numerous seastacks 

and rocky outcrops along the Sanctuary shoreline, coupled with a large tidal range and wave 

splash zone, support some of the most diverse and complex intertidal zones in the United States.

The Sanctuary provides an essential habitat for a wide variety of marine mammals and birds, and 

is of particular interest due to the presence of endangered and threatened species that live or 

migrate through the region. Twenty seven species of marine mammals are reported to breed, rest 

within, or migrate offshore of the Olympic Peninsula. Of particular interest is the migration route 

of the endangered California gray whale, the threatened northern sea lion, the occasional 

presence of the endangered right, fin, sei, blue, humpback, and sperm whales, and the 

reintroduced resident population of sea otters.

In addition, the seabird colonies of Washington's outer coast are among the largest in the 

continental United States and include a number of species listed as endangered or threatened 

including the short-tailed albatross, peregrine falcon, brown pelican, Aleutian Canada goose, 

marbled murrelet, and one of the largest populations of bald eagles in the continental United 

States.

The high biological productivity of the coastal and offshore waters in the Sanctuary support 

valuable fisheries that contribute significantly to the State and tribal economies. The 

commercially important species of fish include five species of salmon, groundfish, and shellfish.

In addition to the Sanctuary's value with respect to its biological resources, the region 

encompasses significant historical resources including Indian village sites, ancient canoe runs, 

petroglyphs, Indian artifacts, and numerous shipwrecks.
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APPENDIX A – TERMS OF DESIGNATION

The diversity and richness of marine resources suggests that the marine sanctuary designations 

will provide exceptional opportunities for scientific research in the areas of species interactions, 

population dynamics, physiological ecology, linkages between terrestrial and aquatic 

ecosystems, and marine anthropology. The scientific research encouraged by the Sanctuary

management plan will, in turn, help support an intensive public education and awareness 

program that will address the diverse, complex, and sensitive ecosystems in Washington's coastal 

and oceanic environments.

Article IV. Scope of Regulations

Section 1. Activities Subject to Regulation

The following activities are subject to regulation, including prohibition, to the extent necessary 

and reasonable to ensure the protection and management of the conservation, ecological, 

recreational, research, educational, historical and aesthetic resources and qualities of the area:

a. Exploring for, developing, or producing oil, gas or minerals (e.g., clay, stone, sand, 

metalliferous ores, gravel, non-metalliferous ores or any other solid material or other 

solid matter of commercial value) within the Sanctuary;

b. Discharging or depositing from within the boundary of the Sanctuary, any material or 

other matter;

c. Discharging or depositing, from beyond the boundary of the Sanctuary, any material or 

other matter;

d. Taking, removing, moving, catching, collecting, harvesting, feeding, injuring, destroying 

or causing the loss of, or attempting to take, remove, move, catch, collect, harvest, feed, 

injure, destroy or cause the loss of, a marine mammal, sea turtle, seabird, historical 

resource or other Sanctuary resource;

e. Drilling into, dredging, or otherwise altering the seabed of the Sanctuary; or 

constructing, placing, or abandoning any structure, material or other matter on the 

seabed of the Sanctuary;

f. Possessing within the Sanctuary a Sanctuary resource or any other resource, regardless 

of where taken, removed, moved, caught, collected or harvested, that, if it had been 

found within the Sanctuary, would be a Sanctuary resource;

g. Flying a motorized aircraft above the Sanctuary;

h. Operating a vessel (i.e., watercraft of any description in the Sanctuary;

i. Interfacing with, obstructing, delaying or preventing an investigation, search, seizure or 

disposition of seized property in connection with enforcement of the Act or any 

regulation or permit issued under the Act.

Section 2. Emergencies

Where necessary to prevent or minimize the destruction of, loss of, or injury to a Sanctuary

resource or quality, or minimize the imminent risk of such destruction, loss or injury, any and all 
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APPENDIX A – TERMS OF DESIGNATION

activities, including those not listed in Section 1 of this Article, are subject to immediate 

temporary regulation, including prohibition.

Article V. Effect on Leases, Permits, Licenses, and Rights

Pursuant to section 304(c)(1) of the Act, 16 U.S.C. 1434(c)(1), no valid lease, permit, license, or 

other authorization issued by any Federal, State, or local authority of competent jurisdiction, or 

any right of subsistence use of access, may be terminated by the Secretary of Commerce or 

designee as a result of this designation. The Secretary of Commerce or designee, however, may 

regulate the exercise (including, but not limited to, the imposition of terms and conditions) of 

such authorization or right consistent with the purposes for which the Sanctuary is designated.

In no event may the Secretary or designee issue a permit authorizing, or otherwise approve: (1) 

Exploration for, development or production of oil, gas or minerals within the Sanctuary; (2) the 

discharge of primary treated sewage (except for regulation, pursuant to section 304(c)(2) of the 

Act, of the exercise of valid authorizations in existence on the effective date of Sanctuary

designation and issued by other authorities of competent jurisdiction); (3) the disposal of dredged 

material within the Sanctuary other than in connection with beach nourishment projects related 

to harbor maintenance activities; or (4) bombing activities within the Sanctuary. Any purported 

authorizations issued by other authorities after the effective date of Sanctuary designation for any 

of these activities within the Sanctuary shall be invalid.

Article VI. Alteration of This Designation

The terms of designation, as defined under Section 304(a) of the Act, may be modified only by 

the same procedures by which the original designation is made, including public hearings 

consultation with interested Federal, State, and local agencies, review by the appropriate 

Congressional committees and the Governor of the State of Washington, and approval by the 

Secretary of Commerce or designee.
253

APPENDIX B – NOTICE OF INTENT FOR INITIATION OF

MANAGEMENT PLAN REVIEW
254
255

APPENDIX B – NOTICE OF INTENT FOR INITIATION OF MANAGEMENT PLAN REVIEW
256

APPENDIX B – NOTICE OF INTENT FOR INITIATION OF MANAGEMENT PLAN REVIEW
257

APPENDIX C – INITIATION OF SECTION 106 CONSULTATION
258
259

APPENDIX C – INITIATION OF SECTION 106 CONSULTATION

261

APPENDIX D – ENHANCING THE INTERGOVERNMENTAL 

PARTNERSHIP (EO 12875)
262
263

APPENDIX D – ENHANCING THE INTERGOVERNMENTAL PARTNERSHIP (EO 12875)
264

APPENDIX D – ENHANCING THE INTERGOVERNMENTAL PARTNERSHIP (EO 12875)
265

APPENDIX E – EXECUTIVE ORDER 12898
266
267

APPENDIX E – EXECUTIVE ORDER 12898
268

APPENDIX E – EXECUTIVE ORDER 12898
269

APPENDIX E – EXECUTIVE ORDER 12898
270

APPENDIX E – EXECUTIVE ORDER 12898
271

APPENDIX E – EXECUTIVE ORDER 12898

273

APPENDIX F – SECRETARIAL ORDER 3206
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275

APPENDIX F – SECRETARIAL ORDER 3206

SECRETARIAL ORDER NO. 3206

SIGNATURE DATE: June 5, 1997

Subject: American Indian Tribal Rights, Federal-Tribal Trust Responsibilities, and the Endangered 

Species Act

Sec. 1 Purpose and Authority. This Order is issued by the Secretary of the Interior and the 

Secretary of Commerce (Secretaries) pursuant to the Endangered Species Act of 1973, 16 U.S.C. 

'1531, as amended (the Act), the federal-tribal trust relationship, and other federal law. Specifically, 

this Order clarifies the responsibilities of the component agencies, bureaus and offices of the 

Department of the Interior and the Department of Commerce (Departments), when actions taken 

under authority of the Act and associated implementing regulations affect, or may affect, Indian 

lands, tribal trust resources, or the exercise of American Indian tribal rights, as defined in this Order. 

This Order further acknowledges the trust responsibility and treaty obligations of the United States 

toward Indian tribes and tribal members and its government-to-government relationship in dealing 

with tribes. Accordingly, the Departments will carry out their responsibilities under the Act in a 

manner that harmonizes the Federal trust responsibility to tribes, tribal sovereignty, and statutory 

missions of the Departments, and that strives to ensure that Indian tribes do not bear a 

disproportionate burden for the conservation of listed species, so as to avoid or minimize the 

potential for conflict and confrontation.

Sec. 2 Scope and Limitations. (A) This Order is for guidance within the Departments only and is 

adopted pursuant to, and is consistent with, existing law.

(B) This Order shall not be construed to grant, expand, create, or diminish any legally enforceable 

rights, benefits or trust responsibilities, substantive or procedural, not otherwise granted or created 

under existing law. Nor shall this Order be construed to alter, amend, repeal, interpret or modify 

tribal sovereignty, any treaty rights, or other rights of any Indian tribe, or to preempt, modify or 

limit the exercise of any such rights.

(C) This Order does not preempt or modify the Departments' statutory authorities or the authorities 

of Indian tribes or the states.

(D) Nothing in this Order shall be applied to authorize direct (directed) take of listed species, or any 

activity that would jeopardize the continued existence of any listed species or destroy or adversely 

modify designated critical habitat. Incidental take issues under this Order are addressed in Principle 

3(C) of Section 5.

(E) Nothing in this Order shall require additional procedural requirements for substantially 

completed Departmental actions, activities, or policy initiatives.

(F) Implementation of this Order shall be subject to the availability of resources and the 

requirements of the Anti-Deficiency Act.
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APPENDIX F – SECRETARIAL ORDER 3206

(G) Should any tribe(s) and the Department(s) agree that greater efficiency in the implementation 

of this Order can be achieved, nothing in this Order shall prevent them from implementing 

strategies to do so.

(H) This Order shall not be construed to supersede, amend, or otherwise modify or affect the 

implementation of, existing agreements or understandings with the Departments or their agencies, 

bureaus, or offices including, but not limited to, memoranda of understanding, memoranda of 

agreement, or statements of relationship, unless mutually agreed by the signatory parties.

Sec. 3 Definitions. For the purposes of this Order, except as otherwise expressly provided, the 

following terms shall apply:

(A) The term "Indian tribe" shall mean any Indian tribe, band, nation, pueblo, community or other 

organized group within the United States which the Secretary of the Interior has identified on the 

most current list of tribes maintained by the Bureau of Indian Affairs.

(B) The term "tribal trust resources" means those natural resources, either on or off Indian lands, 

retained by, or reserved by or for Indian tribes through treaties, statutes, judicial decisions, and 

executive orders, which are protected by a fiduciary obligation on the part of the United States.

(C) The term "tribal rights" means those rights legally accruing to a tribe or tribes by virtue of 

inherent sovereign authority, unextinguished aboriginal title, treaty, statute, judicial decisions, 

executive order or agreement, and which give rise to legally enforceable remedies.

(D) The term "Indian lands" means any lands title to which is either: 1) held in trust by the United 

States for the benefit of any Indian tribe or individual; or 2) held by any Indian tribe or individual 

subject to restrictions by the United States against alienation.

Sec. 4 Background. The unique and distinctive political relationship between the United States 

and Indian tribes is defined by treaties, statutes, executive orders, judicial decisions, and 

agreements, and differentiates tribes from other entities that deal with, or are affected by, the federal 

government. This relationship has given rise to a special federal trust responsibility, involving the 

legal responsibilities and obligations of the United States toward Indian tribes and the application of 

fiduciary standards of due care with respect to Indian lands, tribal trust resources, and the exercise 

of tribal rights.

The Departments recognize the importance of tribal self-governance and the protocols of a 

government-to-government relationship with Indian tribes. Long-standing Congressional and 

Administrative policies promote tribal self-government, self-sufficiency, and self-determination, 

recognizing and endorsing the fundamental rights of tribes to set their own priorities and make 

decisions affecting their resources and distinctive ways of life. The Departments recognize and 

respect, and shall consider, the value that tribal traditional knowledge provides to tribal and federal 

land management decision-making and tribal resource management activities. The Departments 

recognize that Indian tribes are governmental sovereigns; inherent in this sovereign authority is the 

power to make and enforce laws, administer justice, manage and control Indian lands, exercise tribal 

rights and protect tribal trust resources. The Departments shall be sensitive to the fact that Indian 
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APPENDIX F – SECRETARIAL ORDER 3206

cultures, religions, and spirituality often involve ceremonial and medicinal uses of plants, animals, 

and specific geographic places.

Indian lands are not federal public lands or part of the public domain, and are not subject to federal 

public land laws. They were retained by tribes or were set aside for tribal use pursuant to treaties, 

statutes, judicial decisions, executive orders or agreements. These lands are managed by Indian 

tribes in accordance with tribal goals and objectives, within the framework of applicable laws.

Because of the unique government-to-government relationship between Indian tribes and the United 

States, the Departments and affected Indian tribes need to establish and maintain effective working 

relationships and mutual partnerships to promote the conservation of sensitive species (including 

candidate, proposed and listed species) and the health of ecosystems upon which they depend. Such 

relationships should focus on cooperative assistance, consultation, the sharing of information, and 

the creation of government-to-government partnerships to promote healthy ecosystems. 

In facilitating a government-to-government relationship, the Departments may work with intertribal 

organizations, to the extent such organizations are authorized by their member tribes to carry out 

resource management responsibilities.

Sec. 5 Responsibilities. To achieve the objectives of this Order, the heads of all agencies, bureaus 

and offices within the Department of the Interior, and the Administrator of the National Oceanic and 

Atmospheric Administration (NOAA) within the Department of Commerce, shall be responsible for 

ensuring that the following directives are followed:

Principle 1. THE DEPARTMENTS SHALL WORK DIRECTLY WITH INDIAN TRIBES 

ON A GOVERNMENT-TO-GOVERNMENT BASIS TO PROMOTE HEALTHY 

ECOSYSTEMS.

The Departments shall recognize the unique and distinctive political and constitutionally based 

relationship that exists between the United States and each Indian tribe, and shall view tribal 

governments as sovereign entities with authority and responsibility for the health and welfare of 

ecosystems on Indian lands. The Departments recognize that Indian tribes are governmental 

sovereigns with inherent powers to make and enforce laws, administer justice, and manage and 

control their natural resources. Accordingly, the Departments shall seek to establish effective 

government-to-government working relationships with tribes to achieve the common goal of 

promoting and protecting the health of these ecosystems. Whenever the agencies, bureaus, and 

offices of the Departments are aware that their actions planned under the Act may impact tribal trust 

resources, the exercise of tribal rights, or Indian lands, they shall consult with, and seek the 

participation of, the affected Indian tribes to the maximum extent practicable. This shall include 

providing affected tribes adequate opportunities to participate in data collection, consensus seeking, 

and associated processes. To facilitate the government-to-government relationship, the 

Departments may coordinate their discussions with a representative from an intertribal organization, 

if so designated by the affected tribe(s).

Except when determined necessary for investigative or prosecutorial law enforcement activities, or 

when otherwise provided in a federal-tribal agreement, the Departments, to the maximum extent 
278

APPENDIX F – SECRETARIAL ORDER 3206

practicable, shall obtain permission from tribes before knowingly entering Indian reservations and 

tribally-owned fee lands for purposes of ESA-related activities, and shall communicate as necessary 

with the appropriate tribal officials. If a tribe believes this section has been violated, such tribe may 

file a complaint with the appropriate Secretary, who shall promptly investigate and respond to the 

tribe.

Principle 2. THE DEPARTMENTS SHALL RECOGNIZE THAT INDIAN LANDS ARE 

NOT SUBJECT TO THE SAME CONTROLS AS FEDERAL PUBLIC LANDS.

The Departments recognize that Indian lands, whether held in trust by the United States for the use 

and benefit of Indians or owned exclusively by an Indian tribe, are not subject to the controls or 

restrictions set forth in federal public land laws. Indian lands are not federal public lands or part of 

the public domain, but are rather retained by tribes or set aside for tribal use pursuant to treaties, 

statutes, court orders, executive orders, judicial decisions, or agreements. Accordingly, Indian tribes 

manage Indian lands in accordance with tribal goals and objectives, within the framework of 

applicable laws.

Principle 3. THE DEPARTMENTS SHALL ASSIST INDIAN TRIBES IN DEVELOPING 

AND EXPANDING TRIBAL PROGRAMS SO THAT HEALTHY ECOSYSTEMS ARE 

PROMOTED AND CONSERVATION RESTRICTIONS ARE UNNECESSARY.

(A) The Departments shall take affirmative steps to assist Indian tribes in developing and 

expanding tribal programs that promote healthy ecosystems.

The Departments shall take affirmative steps to achieve the common goals of promoting healthy 

ecosystems, Indian self-government, and productive government-to-government relationships under 

this Order, by assisting Indian tribes in developing and expanding tribal programs that promote the 

health of ecosystems upon which sensitive species (including candidate, proposed and listed 

species) depend.

The Departments shall offer and provide such scientific and technical assistance and information as 

may be available for the development of tribal conservation and management plans to promote the 

maintenance, restoration, enhancement and health of the ecosystems upon which sensitive species 

(including candidate, proposed, and listed species) depend, including the cooperative identification 

of appropriate management measures to address concerns for such species and their habitats.

(B) The Departments shall recognize that Indian tribes are appropriate governmental entities 

to manage their lands and tribal trust resources.

The Departments acknowledge that Indian tribes value, and exercise responsibilities for, 

management of Indian lands and tribal trust resources. In keeping with the federal policy of 

promoting tribal self-government, the Departments shall respect the exercise of tribal sovereignty 

over the management of Indian lands, and tribal trust resources. Accordingly, the Departments shall 

give deference to tribal conservation and management plans for tribal trust resources that: (a) govern 

activities on Indian lands, including, for the purposes of this section, tribally-owned fee lands, and 

(b) address the conservation needs of listed species. The Departments shall conduct government-to-
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APPENDIX F – SECRETARIAL ORDER 3206

government consultations to discuss the extent to which tribal resource management plans for tribal 

trust resources outside Indian lands can be incorporated into actions to address the conservation 

needs of listed species.

(C) The Departments, as trustees, shall support tribal measures that preclude the need for 

conservation restrictions.

At the earliest indication that the need for federal conservation restrictions is being considered for 

any species, the Departments, acting in their trustee capacities, shall promptly notify all potentially 

affected tribes, and provide such technical, financial, or other assistance as may be appropriate, 

thereby assisting Indian tribes in identifying and implementing tribal conservation and other 

measures necessary to protect such species.

In the event that the Departments determine that conservation restrictions are necessary in order to 

protect listed species, the Departments, in keeping with the trust responsibility and government-togovernment relationships, shall consult with affected tribes and provide written notice to them of the 

intended restriction as far in advance as practicable. If the proposed conservation restriction is 

directed at a tribal activity that could raise the potential issue of direct (directed) take under the Act, 

then meaningful government-to-government consultation shall occur, in order to strive to harmonize 

the federal trust responsibility to tribes, tribal sovereignty and the statutory missions of the 

Departments. In cases involving an activity that could raise the potential issue of an incidental take 

under the Act, such notice shall include an analysis and determination that all of the following 

conservation standards have been met: (i) the restriction is reasonable and necessary for 

conservation of the species at issue; (ii) the conservation purpose of the restriction cannot be 

achieved by reasonable regulation of non-Indian activities; (iii) the measure is the least restrictive 

alternative available to achieve the required conservation purpose; (iv) the restriction does not 

discriminate against Indian activities, either as stated or applied; and, (v) voluntary tribal measures 

are not adequate to achieve the necessary conservation purpose.

Principle 4. THE DEPARTMENTS SHALL BE SENSITIVE TO INDIAN CULTURE, 

RELIGION AND SPIRITUALITY.

The Departments shall take into consideration the impacts of their actions and policies under the Act 

on Indian use of listed species for cultural and religious purposes. The Departments shall avoid or 

minimize, to the extent practicable, adverse effects upon the noncommercial use of listed sacred 

plants and animals in medicinal treatments and in the expression of cultural and religious beliefs by 

Indian tribes. When appropriate, the Departments may issue guidelines to accommodate Indian 

access to, and traditional uses of, listed species, and to address unique circumstances that may exist 

when administering the Act.

Principle 5. THE DEPARTMENTS SHALL MAKE AVAILABLE TO INDIAN TRIBES 

INFORMATION RELATED TO TRIBAL TRUST RESOURCES AND INDIAN LANDS, 

AND, TO FACILITATE THE MUTUAL EXCHANGE OF INFORMATION, SHALL 

STRIVE TO PROTECT SENSITIVE TRIBAL INFORMATION FROM DISCLOSURE.
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APPENDIX F – SECRETARIAL ORDER 3206

To further tribal self-government and the promotion of healthy ecosystems, the Departments 

recognize the critical need for Indian tribes to possess complete and accurate information related to 

Indian lands and tribal trust resources. To the extent consistent with the provisions of the Privacy 

Act, the Freedom of Information Act (FOIA) and the Departments' abilities to continue to assert 

FOIA exemptions with regard to FOIA requests, the Departments shall make available to an Indian 

tribe all information held by the Departments which is related to its Indian lands and tribal trust 

resources. In the course of the mutual exchange of information, the Departments shall protect, to 

the maximum extent practicable, tribal information which has been disclosed to or collected by the 

Departments. The Departments shall promptly notify and, when appropriate, consult with affected 

tribes regarding all requests for tribal information relating to the administration of the Act.

Sec. 6 Federal-Tribal Intergovernmental Agreements. The Departments shall, when 

appropriate and at the request of an Indian tribe, pursue intergovernmental agreements to formalize 

arrangements involving sensitive species (including candidate, proposed, and listed species) such as, 

but not limited to, land and resource management, multi-jurisdictional partnerships, cooperative law 

enforcement, and guidelines to accommodate Indian access to, and traditional uses of, natural 

products. Such agreements shall strive to establish partnerships that harmonize the Departments' 

missions under the Act with the Indian tribe's own ecosystem management objectives.

Sec. 7 Alaska. The Departments recognize that section 10(e) of the Act governs the taking of 

listed species by Alaska Natives for subsistence purposes and that there is a need to study the 

implementation of the Act as applied to Alaska tribes and natives. Accordingly, this Order shall not 

apply to Alaska and the Departments shall, within one year of the date of this Order, develop 

recommendations to the Secretaries to supplement or modify this Order and its Appendix, so as to 

guide the administration of the Act in Alaska. These recommendations shall be developed with the 

full cooperation and participation of Alaska tribes and natives. The purpose of these 

recommendations shall be to harmonize the government-to-government relationship with Alaska 

tribes, the federal trust responsibility to Alaska tribes and Alaska Natives, the rights of Alaska 

Natives, and the statutory missions of the Departments.

Sec. 8 Special Study on Cultural and Religious Use of Natural Products. The Departments 

recognize that there remain tribal concerns regarding the access to, and uses of, eagle feathers, 

animal parts, and other natural products for Indian cultural and religious purposes. Therefore, the 

Departments shall work together with Indian tribes to develop recommendations to the Secretaries 

within one year to revise or establish uniform administrative procedures to govern the possession, 

distribution, and transportation of such natural products that are under federal jurisdiction or control.

Sec. 9 Dispute Resolution. (A) Federal-tribal disputes regarding implementation of this Order 

shall be addressed through government-to-government discourse. Such discourse is to be respectful 

of government-to-government relationships and relevant federal-tribal agreements, treaties, judicial 

decisions, and policies pertaining to Indian tribes. Alternative dispute resolution processes may be 

employed as necessary to resolve disputes on technical or policy issues within statutory time 

frames; provided that such alternative dispute resolution processes are not intended to apply in the 

context of investigative or prosecutorial law enforcement activities.
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APPENDIX F – SECRETARIAL ORDER 3206

(B) Questions and concerns on matters relating to the use or possession of listed plants or listed 

animal parts used for religious or cultural purposes shall be referred to the appropriate Departmental 

officials and the appropriate tribal contacts for religious and cultural affairs.

Sec. 10 Implementation. This Order shall be implemented by all agencies, bureaus, and offices of 

the Departments, as applicable. In addition, the U.S. Fish and Wildlife Service and the National 

Marine Fisheries Service shall implement their specific responsibilities under the Act in accordance 

with the guidance contained in the attached Appendix.

Sec. 11 Effective Date. This Order, issued within the Department of the Interior as Order No. 

3206, is effective immediately and will remain in effect until amended, superseded, or revoked.

This Secretarial Order, entitled "American Indian Tribal Rights, Federal-Tribal Trust 

Responsibilities, and the Endangered Species Act," and its accompanying Appendix were issued 

this 5th day of June, 1997, in Washington, D.C., by the Secretary of the Interior and the Secretary of 

Commerce.

/s/ Bruce Babbitt

Secretary of the Interior

/s/ William M. Daley

Secretary of Commerce

Date: June 5, 1997

283

APPENDIX G – EXECUTIVE ORDER 13084
284
285

APPENDIX G – EXECUTIVE ORDER 13084
286

APPENDIX G – EXECUTIVE ORDER 13084
287

APPENDIX G – EXECUTIVE ORDER 13084

289

APPENDIX H – PRESIDENTIAL MEMORANDUM OF 

NOVEMBER 5, 2009
290
291

APPENDIX H – PRESIDENTIAL MEMORANDUM OF NOVEMBER 5, 2009
292

APPENDIX H – PRESIDENTIAL MEMORANDUM OF NOVEMBER 5, 2009
293

APPENDIX I – EXECUTIVE ORDER 13175
294
295

APPENDIX I – EXECUTIVE ORDER 13175
296

APPENDIX I – EXECUTIVE ORDER 13175
297

APPENDIX I – EXECUTIVE ORDER 13175
298

APPENDIX I – EXECUTIVE ORDER 13175
299

APPENDIX J – DEPARTMENT OF COMMERCE AMERICAN 

INDIAN AND ALASKA NATIVE POLICY
300
301

APPENDIX J – DEPARTMENT OF COMMERCE AMERICAN INDIAN AND ALASKA NATIVE POLICY
302

APPENDIX J – DEPARTMENT OF COMMERCE AMERICAN INDIAN AND ALASKA NATIVE POLICY
303

APPENDIX J – DEPARTMENT OF COMMERCE AMERICAN INDIAN AND ALASKA NATIVE POLICY
304

APPENDIX J – DEPARTMENT OF COMMERCE AMERICAN INDIAN AND ALASKA NATIVE POLICY
305

APPENDIX K – DISCHARGE ESTIMATION METHODOLOGY
306
307

APPENDIX K – DISCHARGE ESTIMATION METHODOLOGY

Information regarding vessel transits, including distance and time in the sanctuary was obtained 

from three different sources of information:

 Cooperative Vessel Traffic Service (CVTS) radar data

 NMFS Vessel Monitoring System (VMS) satellite data

 WDFW Recreational Fishing Data, collected by Port Sampling Staff

This information was used to develop estimates on vessel discharges in the sanctuary in 2009. 

2009 was chosen for analysis because it was the most recent period for which complete 

information existed for each of the three data sources. While each of these data sources collects 

data for different purposes and contains different information, they have in common information 

that lends itself to an overall assessment of vessel usage with the sanctuary. In order to develop 

discharge estimates certain data was estimated.

Table 19 Comparison of vessel data sources

Data 

Source Type of Vessel # of Transits Spatial Information

Time in 

Sanctuary

# of 

Passengers

CVTS

Vessels participating in 

vessel traffic system - mostly 

large commercial vessels

YES – each 

transit has a 

unique ID

YES

YES– needed to be 

calculated based on 

point data

NO –

estimated

NMFS

Commercial fishing vessels 

required by fisheries 

management plan to carry 

VMS system

NO– estimated 

number of transits 

was calculated

YES

YES– needed to be 

calculated based on 

point data

NO –

estimated

WDFW

Washington State 

recreational fishers (includes 

charter vessels)

YES –

summarized by 

boat trip

PARTIALLY –

reported by Marine 

Areas, estimated % 

time within OCNMS.

NO – time per trip 

was estimated

YES –

summarized 

by angler trips

Cooperative Vessel Traffic Service (CVTS) Radar Data

This data is collected by the Canadian Coast Guard Marine Communications and Traffic 

Services (MCTS) and includes all vessels participating in the Cooperative Vessel Traffic 

(CVTS). This data is forwarded to OCNMS, which imports the information into a Geographic 

Information System (GIS) system. For each class of vessel class, the number of “vessel days per 

year” (the total combined time all vessels within a given class spent within OCMNS waters in 

2009) was calculated from CVTS data. The range of the CVTS radar does not cover the whole 

sanctuary (Figure 15) but it does cover the northern portion of the sanctuary where vessels 

complying with the ATBA (estimated at >98% of vessels) are transiting sanctuary waters. 

Vessels in compliance with the ATBA can traverse a small portion of the sanctuary in the south, 

so the time estimates calculated by this method can provide a small underestimate of time in 

sanctuary, which in turn could result in an underestimate of total discharge. This is the 

sanctuary‟s primary source of vessel traffic data. This data was used for the following Vessel 

Classes (Table 6 and Table 7):

 Commercial Vessels < 300 GT

 Commercial Vessels 300-1599 GT 

 Commercial Vessels > 1600 GT
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APPENDIX K – DISCHARGE ESTIMATION METHODOLOGY

 Passenger Vessels < 300 GT

 Passenger Vessels 300-1599 GT 

 Passenger Vessels > 1600 GT

 Public Vessels < 300 GT

 Public Vessels 300-1599 GT

 Public Vessels > 1600 GT

 Tank Vessels < 1600 GT

 Tank Vessels > 1600 GT

 Tug with Tank Barge

Figure 15 Extent of the Canadian Coast Guard radar coverage within OCNMS
309

APPENDIX K – DISCHARGE ESTIMATION METHODOLOGY

NMFS Vessel Monitoring System (VMS) Satellite Data

National Marine Fisheries Service Northwest Region and the Pacific Fisheries Management 

Council have a vessel monitoring program to monitor compliance with areas closed to fishing. 

The program utilizes a satellite based Vessel Monitoring System (VMS) that reports the position 

of participating vessels. NMFS provided OCNMS with point data for VMS participating vessels 

within the sanctuary during 2009. There were 52,015 points, representing 171 individual vessels 

that met these criteria. Not all information from the VMS database was provided for the 

analysis, e.g., while unique vessel ID‟s were provided they cannot be used to identify the 

vessel‟s name. The data points were sorted by time, then boat ID. Transit ID‟s were then added, 

incrementing the transit ID number any time the boat ID changed, or the boat ID was the same 

but the time jumped by more than 6 hours. Each transit ID contains a continuous set of points 

for one boat with no more than 6 contiguous hours of missing points. Therefore, for the 

purposes of this analysis a transit is defined by time in the sanctuary, not the duration of time 

between port calls. If a fishing vessel is fishing part time in the sanctuary and part time out, then 

their fishing trip might be broken into multiple transits. This analysis resulted in an estimate of 

3,006 fishing transits in the sanctuary for a total of 1,577 vessel days for 2009. This information 

was used for the Commercial Fishing Vessel Class (Table 6 and Table 7):

WDFW Recreational Fishing Data

As part of their Port Sampling Program, WDFW collects information on recreational fishing 

activity. This data is reports both boat trips and angler trips, by WDFW Marine Areas 

(Figure 16). The sanctuary boundaries include all of Marine Areas 3 and 4 and approximately 

28% on 4B and 29% of Marine Area 2. For the purpose of this analysis we assumed boat trips 

and angler trips were equally distributed throughout the reporting area, and each boat trip lasted 

an estimated six hours. Actual distribution will vary according to the location of preferred fishing 

areas, distance from port and weather conditions.

After estimating the number of boat trips in OCNMS in 2009 (10,351 private and 1,148 charter) 

(Table 20), an average was calculated for number of anglers per trip (2.8 private and 10.6 charter) 

(Table 21). This information was used to for the following Vessel Class (Table 6 and Table 7):

 Charter Fishing Vessel

 Recreational Fishing Vessel

Table 20 Recreational fishing boat trips, within OCNMS, for 2009

2009 Marine 

Area

Boat Trips in Entire Marine 

Area Boat Trips in OCNMS

Private Charter Total % of area 

in OCNMS Private Charter Total

Neah Bay-straits 4B 6,401 34 6,435 28% 1,792 10 1,802

Neah Bay -coast 4 3,607 120 3,727 100% 3,607 120 3,727

La Push 3 2,760 343 3,103 100% 2,760 343 3,103

Westport 2 7,556 2,329 9,885 29% 2,191 675 2,867

Total 20,324 2,826 23,150 10,351 1,148 11,498
310

APPENDIX K – DISCHARGE ESTIMATION METHODOLOGY

Figure 16 WDFW Marine Areas and OCNMS Boundary

Annual Discharge Volume (ADV) Calculation

Annual discharge volume (ADV) estimates for each vessel class was calculated using 

Equation 1 based on the number of vessel days per year in the OCNMS, the number of people 

aboard (including passengers and crew), and the average wastewater generation rate per person. 

It is difficult to estimate the exact quantity of sewage generated per person per day because 

variable volumes of water are used to flush different types of toilets. Product information for 

three popular type II MSDs (The Tank MSD®, Ahead Tank®, and Orca®) suggest wastewater 

generation rates of 5.5, 9.2, and 30 gallons of blackwater generated per person per day, 

respectively. Measured sewage wastewater generation rates of cruise ships in Alaska in 2004 

ranged from 1.1 gallons to 27 gallons per person per day (EPA 2008a), indicating the wastewater 

generation rate estimates provided by MSD manufacturers fall within a reasonable range. 
311

APPENDIX K – DISCHARGE ESTIMATION METHODOLOGY

Because of the potential variability in waste generation rate, a minimum, average, and high 

estimate, based on hypothetical sewage generation rates of 5.5, 15 and 30 gallons of waste per 

person per day are reported in Table 6. The average waste generation rate was calculated as the 

mean of the MSD product information rates identified above.

Table 21 Recreational fishing angler trips, within OCNMS, for 2009

Marine 

Area

Angler Trips in Entire Marine 

Area Angler Trips in OCNMS

Average 

Anglers/Vessel in 

OCNMS

Private Charter Total % of area in 

OCNMS Private Charter Total Private Charter

4B 16,905 127 17,032 28% 4,733 36 4,769 2.6 3.7

4 10,497 742 11,239 100% 10,497 742 11,239 2.9 6.2

3 7,832 2,157 9,989 100% 7,832 2,157 9,989 2.8 6.3

2 20,869 31,814 52,683 29% 6,052 9,226 15,278 2.8 13.7

Total 56,103 34,840 90,943 29,114 12,161 41,275 2.8 10.6

Some vessels have the ability to hold treated sewage effluent for a period of hours to days, 

depending holding tank size. However, even with these systems, the overall average discharge 

rate must equal the waste generation rate. For this reason, the discharge rate used in calculations 

is assumed to equal the waste generation rate. Because recreational fishing vessels, in general, 

have minimal kitchen and showering capacity and are day use only, this vessel class was not 

included in estimates of graywater discharges.

The volume of graywater generated on vessels less than 79 feet varied widely depending on type 

of vessel, ranging from a few to several hundred gallons/vessel/day. Estimated graywater 

generation rates of 36, 67, and 119 gallons/person/per day (U.S. EPA 2008a) are reported in Table

7.

 

Equation 1 

where:

ADV: Annual Discharge Volume

VDY: Vessel Days per Year

N: Number of passengers aboard vessel

WGR: Waste generated per person per day 
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APPENDIX K – DISCHARGE ESTIMATION METHODOLOGY

Wastewater Treatment System Descriptions

The Federal Water Pollution Control Act, also informally called the Clean Water Act or CWA 

(33 U.S.C.1251 et seq.), requires any vessel with installed toilet facilities must also have an 

operable MSD. Three general types of MSDs are available and in use. Type I and II MSDs treat 

the wastewater before its discharge or transfer. Type III MSDs are storage tanks which retain 

waste until it can be disposed of at an appropriate pump-out facility or at sea. 

 Type I MSDs rely on maceration and chemical disinfection for treatment of the waste 

prior to its discharge into the water, and are only legal in vessels under 65 feet in length 

(U.S. EPA 2010a). USCG regulations dictate that effluent from Type I MSDs may not 

have a fecal coliform count greater than 1,000 per 100 milliliters, nor visible floating 

solids (USCG 2009).

 Type II MSDs provide an advanced form of the same type of treatment used by Type I 

MSDs and have a greater capacity to reduce fecal coliform counts and suspended solids. 

Different from Type I MSDs which rely solely on maceration to break down solid waste, 

Type II MSDs utilize aeration and aerobic bacteria in addition to maceration for the 

breakdown of solids. As with Type I MSDs, the waste is chemically disinfected, 

typically with chlorine, ammonia or formaldehyde, prior to discharge. Type II MSDs are 

legal in any size class of vessel, and there are a variety of different types (U.S. EPA 

2008b). USCG regulations prohibit discharge of effluent from Type II MSDs with fecal 

coliform counts greater than 200 per 100 milliliters or suspended solids greater than 

150 milligrams per liter (USCG 2009).

 Advanced wastewater treatment systems (AWTS) are an advanced form of Type II MSD 

utilizing techniques such as reverse osmosis and UV sterilization to provide more 

effective treatment. The performance of these units far surpasses the standards for fecal 

coliform bacteria, as well as other pollutants, set forth for Type II MSDs. In addition, 

AWTS typically produce „clean‟ discharge waste containing substantially lower 

concentrations of hazardous treatment chemicals (U.S. EPA 2008a). 

 Type III MSDs, commonly called holding tanks, flush sewage from the marine head into 

a tank that may contain deodorizers and other chemicals, predominantly chlorine. The 

contents of the holding tank are stored until they can be properly disposed of at a shoreside pump-out facility, or discharged off shore. Storing wastewater in holding tanks can 

increase fecal coliform counts and total suspended solids (ADEC 2000). Type III MSDs 

can be equipped with a discharge option, usually called a Y-valve, which directs the 

sewage into either the holding tank or directly overboard.
313

APPENDIX L – RESPONSES TO COMMENTS
314
315

APPENDIX L – RESPONSES TO COMMENTS

RESPONSE TO COMMENTS

The National Oceanic and Atmospheric Administration (NOAA) conducted two public hearings 

to gather input on the Olympic Coast National Marine Sanctuary (OCNMS) draft management 

plan/environmental assessment and proposed rule during the public comment period from 

January 14 through March 25, 2011. All written and verbal comments received during the public 

comment period were compiled and grouped into general topics. Similar comments from 

multiple submissions have been treated as one comment for purposes of response. NOAA 

considered all of these comments and, where appropriate, made changes to the final management 

plan (FMP) and environmental assessment (EA) in response to the comments. Editorial 

comments on the FMP/EA were also taken under consideration by NOAA and, where 

appropriate, applied to the EA or FMP. These comments are not included in the list below due to 

their editorial nature. Substantive comments received are summarized below, followed by 

NOAA‟s response. 

GENERAL COMMENTS

Comment: The collaborative nature of the OCNMS management plan review (MPR) process is 

appreciated. The 20 action plans in the management plan and the regulatory actions presented as 

Alternative B in the environmental assessment appropriately and thoroughly represent the 

highest priorities for OCNMS.

Response: NOAA appreciates the support it received from the OCNMS Advisory Council 

(SAC), Olympic Coast Intergovernmental Policy Council (IPC), interested groups, 

organizations and individuals in developing the DMP, and in particular the 20 action plans. 

NOAA also appreciates the support for Alternative B and has selected it as the basis for the 

final management plan.

Comment: NOAA should prioritize particular action plans, strategies, or activities and develop 

appropriate staffing strategies to implement the final management plan (FMP). 

Response: The action plans in the FMP comprise an ambitious body of work. For that 

reason, prioritization of action plans and strategies in the FMP is essential. NOAA worked 

with the SAC and the IPC in order to develop the implementation strategy provided in Table

5 in the FMP. This implementation table categorizes strategies as high, medium and low 

priorities for OCNMS under three different, hypothetical budget scenarios. NOAA will use 

the implementation table to consider priorities for operations on an annual basis. Future 

organizational structure and staffing decisions will be based on this prioritization of the 

strategies in the FMP, as well as the skills needed to implement the FMP. Because there is 

uncertainty about how future funding levels will influence prioritization, NOAA did not 

include a specific organizational structure or staffing plan in the FMP.

Comment: The final management plan should clarify and specify that the highest priority 

management goal of the Olympic Coast National Marine Sanctuary continues to be, "the 

protection of the marine environment and resources and qualities of the Sanctuary."
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APPENDIX L – RESPONSES TO COMMENTS

Response: Resource protection is the primary objective identified in the National Marine 

Sanctuaries Act (NMSA) and is, therefore, the highest priority for OCNMS. The six priority 

management needs and the goals and objectives for OCNMS outlined in the FMP were 

developed collaboratively through a public process with the SAC and the IPC. The OCNMS 

goals and objectives are not presented in an explicitly prioritized order; they are all 

considered important to OCNMS in the context of resource protection. 

Comment: To avoid confusion among members of the public, NOAA should make clear that 

there are other, ongoing NOAA regulatory actions separate from the OCNMS management plan 

review process.

Response: At any given time, NOAA may have a number of regulatory actions in progress, 

some of which may affect OCNMS. For example, the ONMS has recently proposed a rule 

addressing disturbances of wildlife by aircraft flying over national marine sanctuaries (75 FR 

76319). Other NOAA regulatory actions include fishery management actions under the 

Magnuson-Stevens Conservation and Management Act, authorizations under the Marine 

Mammal Protection Act, or permits under the Endangered Species Act. 

Comment: NOAA‟s regulatory reach in managing OCNMS has expanded beyond the original 

goal of providing greater protection to tribal treaty fisheries and subsistence resources from the 

harmful effects of offshore oil development and oils spills. 

Response: The 1994 terms of designation for OCNMS states that the sanctuary was 

established for the purposes of protecting and managing the conservation, ecological, 

recreational, research, educational, historical and aesthetic resources and qualities of the area. 

The scope of regulations, as defined in the OCNMS terms of designation, and the regulations 

for OCNMS have not changed since 1994. The few changes to OCNMS regulations 

identified in this rule are within the scope of regulations defined in the OCNMS terms of 

designation. 

Comment: NOAA should release an annual report to the public summarizing the progress made 

with implementation of the OCNMS management plan.

Response: NOAA agrees and plans to produce such a report.

Comment: NOAA should continue its efforts to build and strengthen its relationships with 

communities on the outer coast of the Olympic Peninsula, as well as collaborate with the Lake 

Ozette Sockeye Committee (LOSC) to assist in reducing risk factors for sockeye salmon 

survival. Since collaboration among groups can at times be contentious or volatile, NOAA 

should enlist the assistance of a professional facilitator at meetings to strengthen collaboration 

among key partners. 

Response: NOAA agrees and intends to continue efforts in this area, as identified in multiple 

strategies and activities in the Community Involvement in Sanctuary Management and 

Community Outreach action plans included the FMP. While not an active participant, 

OCNMS staff have been monitoring the work of the LOSC. The Lake Ozette Sockeye 
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Recovery Plan is focused on terrestrial and freshwater management options. Improved 

understanding of marine habitat use by sockeye salmon, particularly juveniles, is important to 

effective management and, perhaps, recovery of this ESA listed species, and NOAA supports 

collaboration on related research within the boundaries of the sanctuary. Several strategies in 

the FMP provide flexibility to consider such collaborations over the 5-10 year 

implementation period for the FMP. In addition, NOAA utilizes professional facilitators on 

occasion, when appropriate. It is not possible, nor necessary, to use professional facilitation 

at all meetings. 

Comment: Electronic submission should not be the primary method used for the public to 

submit comments on these documents because many people living on the West end of the 

Olympic Peninsula do not have internet access. In addition, the products and actions of the IPC 

and the SAC are not sufficiently transparent to the public. 

Response: NOAA accepted comments by several means, including: in writing, orally at 

public hearings, electronic submissions, and by fax. All OCNMS SAC meetings are open to 

the public, as were all the SAC working group meetings and workshops that resulted in 

preliminary draft action plans. These meetings and workshops were announced on the 

OCNMS web site and periodically advertised to the email listserve developed for OCNMS 

MPR. One of the reasons Sanctuary Advisory Councils are an integral part of the 

management plan review process for all sites within the National Marine Sanctuary System is 

to ensure that management plans are reviewed and revised in a public forum. While the IPC 

meetings themselves are not required to be public, in all cases where the IPC provided 

recommendations for the draft management plan, these recommendations were discussed at 

SAC meetings, which are open to the public. Each step of the OCNMS MPR process, 

including meeting notes of all the SAC meetings, has been documented and is publically 

available on the OCNMS website.

Comment: The environmental assessment frequently confuses Endangered Species Act (ESA), 

Marine Mammal Protection Act (MMPA), and National Environmental Policy Act (NEPA) 

"effects" language and conclusions.

Response: The OCNMS EA is written in conformance with the National Environmental 

Policy Act (NEPA)(42 USC § 4332) and NEPA regulations ( 40 CFR § 1500) and does not 

contradict or conflict with language pertaining to adverse impacts or effects contained in 

either the Endangered Species Act or Marine Mammal Protection Act. Phrasing similar to 

threshold language of the ESA and MMPA was used in the EA but was not used in the 

context of characterizing impacts.

Comment: The Desired Outcome stated at the beginning of each sub-plan in the OCNMS 

management plan should be more specifically tailored to a five- or ten-year goal statement where 

one could measure progress or success, and direct efforts for OCNMS, as well as for partners and 

collaborators, as future funding becomes available.

Response: The Desired Outcome statements are intended to be a broader characterization of 

the end result that OCNMS hopes to achieve with each action plan. The desired outcomes 
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are intended to tie each action plan to the goals and objectives outlined at the beginning of 

the management plan. The performance measures identified in the FMP are intended to be 

the specific measures of progress or success.

Comment: NOAA should pursue inter-governmental agreements or memoranda of agreement 

(MOAs) to declassify appropriate U.S. Navy maps and bathymetric data. 

Response: NOAA agrees and has edited two strategies to address the issue of U.S. Navy 

bathymetric data acquisition: Collaborative and Coordinated Sanctuary Management Action 

Plan Strategy, Strategy CCM7: United States Navy, Activity B; and Habitat Mapping and 

Classification Action Plan, Strategy MAP1: Regional Coordination, Activity C.

OIL SPILL PLANNING AND PREVENTION

Comment: NOAA should develop a marine nearshore assessment to determine if sockeye 

populate the region, and improve the regional Geographic Response Plans that direct initial 

response to oil spills.

Response: While conducting a nearshore assessment of sockeye salmon populations is 

beyond its current capacity, NOAA is interested in participating in a collaborative effort to 

conduct such a study. The Spills Prevention, Preparedness, Response and Restoration Action 

Plan, Strategy SPILL3: Regional Planning and Training Exercises, Activity E has been 

modified to seek improvements to geographic response plans in the area of threatened and 

endangered species protection.

Comment: NOAA should remove the activity in the management plan that requests that U.S. 

Coast Guard (USCG) conduct a vessel traffic risk study of the western Strait of Juan de Fuca. 

USCG has reviewed this issue and found aids to navigation adequate in this area.

Response: The recommendation for NOAA to encourage the USCG to conduct a vessel 

traffic study was made by consensus by the Spills Prevention, Preparedness, Response and 

Restoration Working Group. NOAA considers the review of maritime safety within and 

adjacent to sanctuary boundaries to be an ongoing priority. The frequency at which specific 

reviews and studies should be undertaken will be a subject of ongoing discussions between 

NOAA and USCG.

Comment: NOAA should/should not make the Area to be Avoided (ATBA) mandatory.

Response: The ATBA is currently a voluntary vessel traffic measure with a high compliance 

rate (98.9% compliance in 2009) that is routinely monitored by NOAA. Based on the high 

level of compliance, NOAA elected to not support the alternative in the EA (alternative C) 

that would pursue a mandatory ATBA. If compliance rates were to decrease significantly, 

NOAA would revisit this issue after consulting with the USCG and other partners. NOAA 

supports alternative B, which would maintain the voluntary status of the ATBA based on 

high compliance rates.
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SANCTUARY SCIENCE

Comment: NOAA should archive regularly collected satellite data on sea surface temperature 

and primary productivity. 

Response: The collection and archiving of satellite data is the responsibility of NOAA‟s 

National Environmental Satellite, Data, and Information Service (NESDIS). Satellite data 

products including SST and primary productivity indicators (chlorophyll a) are currently 

archived at NESDIS. Most archival data are found in the CLASS system. (Comprehensive 

Large Array-data Stewardship System) at 

http://www.class.ncdc.noaa.gov/saa/products/welcome.

Comment: NOAA should utilize backpackers to help with monitoring efforts in the sanctuary 

(e.g., pass out marine mammal stranding cards, where backpackers could report information).

Response: NOAA believes in the value of citizen science and is a partner in the Coastal 

Observation and Seabird Survey Team (COASST), through which volunteers survey 

designated segments of the coast on a monthly basis. COASST volunteers receive training in 

the monitoring methods to ensure the accuracy and utility of data to resource managers and 

scientists. NOAA does work with Olympic National Park (ONP) staff to provide information 

at trail heads that provides information on how to report marine mammal strandings. NOAA 

is a partner in the Northwest Marine Mammal Stranding Network, which documents and 

coordinates response to marine mammal strandings. NOAA participates in stranding 

network trainings that are provided to ONP‟s coastal rangers and are open to all interested 

parties.

Comment: NOAA should include a representative from the Northwest Fishery Science Center in 

the efforts to develop a list of indicator species for OCNMS. 

Response: NOAA agrees. In strategy ECO9: Ecosystem Processes in the FMP, Northwest 

Fisheries Science Center is identified as a key partner in efforts to identify indicator species 

for the sanctuary area.

NATURAL RESOURCE MANAGEMENT

Comment: The management plan should focus less on collection of more data and should 

contain more explanation of how NOAA will implement ecosystem based management in 

OCNMS in the context of the Coastal and Marine Spatial Planning. 

Response: During development of the management plan, NOAA determined that data 

collection is a priority to support EBM implementation because data on natural resources in 

the sanctuary is still scarce. The FMP directs NOAA to work with its partners over the 

coming years to determine how to implement EBM in the sanctuary region. Collection and 

analysis of data on sanctuary resources are important steps in that direction. Implementation 

of EBM needs to occur on a scale larger than the sanctuary and will require collaboration 

between NOAA, the Coastal Treaty Tribes, the State of Washington, and other partners. 
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Coastal and marine spatial planning (CMSP), as discussed in the FMP, is being implemented 

on a statewide and regional scale. CMSP is a data-dependent process that will be improved 

by more comprehensive characterization of natural resource distribution, condition, and use. 

Comment: NOAA should consider measures such as time/area closures, take limits on prey 

species, and restrictions on fishing activities specifically during the EFH groundfish 5-year 

review.

Response: In the FMP, NOAA does recognize the ecological importance, sensitivity to 

disturbance, and slow recovery potential of biogenic habitats, such as deep sea corals and 

sponges, and is committed to their protection. The Habitat Mapping and Classification 

Action Plan in the FMP supports seafloor habitat mapping, including identifying where 

biogenic habitats occur and sharing these data with other natural resource managers. The 

Habitat Protection Action Plan in the FMP supports OCNMS staff participation in the Pacific 

Fishery Management Council (PFMC) process to identify and review essential fish habitat 

(EFH) and habitat areas of particular concern (HAPC) for Pacific Coast groundfish. This 

action plan also supports collaborative development and evaluation of recommendations for 

HAPC sites and EFH conservation areas. 

Comment: NOAA should define essential fish habitat. Where is it for each species and what are 

the limitations of use within it? 

Response: Essential fish habitat (EFH) is defined in the Magnuson-Stevens Fishery 

Conservation and Management Act as „those waters and substrate necessary to fish for 

spawning, breeding, feeding or growth to maturity‟ (16 U.S.C. § 1802(10)). This Act requires 

NMFS to assist the regional fishery management councils in the implementation of EFH in 

their respective fishery management plans. This Act also requires Federal agencies to 

consult with NMFS on any federal action that may have an adverse effect on EFH. A 

designated groundfish EFH area in OCNMS, named Olympic 2, is identified in the FMP, and 

non-tribal bottom trawlers are prohibited from fishing within Olympic 2. The water column 

in the sanctuary is also designated EFH for Chinook, Coho, and Pink salmon and some 

coastal pelagic species (anchovies, sardines, squid, and mackerel). There are no specific 

fishery management limitations associated with these water column EFH designations. 

Comment: Conservation issues, including any national ONMS initiatives, that may require 

modification of fisheries regulations should be referred to the Pacific Fishery Management 

Council for appropriate action.

Response: In the event modification to Federal fishery regulations is necessary, NOAA will 

bring the issue to the PFMC‟s attention through established processes. At this time, there are 

no national initiatives by the ONMS that would impact Pacific Fisheries Management 

Council-managed species. 

Comment: NOAA should address in the management plan how the access to fishing and 

shellfishing (in this case, the intertidal zone that was deeded to the Federal government) might be 

regulated to adhere to state of Washington requirements. 
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Response: NOAA is not proposing to alter fisheries management through this FMP, 

therefore this issue is beyond the scope of this rulemaking.

Comment: OCNMS‟ goals of protecting, conserving, and enhancing sanctuary resources should 

include the seascape, lightscape and soundscape of OCNMS for this and future generations as it 

relates to the overall recreational hiking experience along that portion of the Washington Coast 

Trail adjacent to the sanctuary. 

Response: As part of the original OCNMS designation in 1994, NOAA described the 

characteristics of the sanctuary that made it an area of special national significance. One 

such characteristic was, “its rugged and undeveloped coastline”. In addition, the National 

Marine Sanctuaries Act identifies both recreational and esthetic qualities as important 

characteristics of national marine sanctuaries. NOAA will consider impacts on these 

characteristics in its review of permit applications for activities in OCNMS. The coastal 

wilderness of Olympic National Park and the Washington Islands National Wildlife Refuges 

are additional federal designations that recognize and protect the Olympic Coast as a special 

and unique area in the continental United States. 

VISITATION AND RECREATION

Comment: NOAA should increase public awareness of the sanctuary resources by making use 

of the natural beauty found above and below the water in a newsletter or a website. 

Response: The desired outcomes of the Visitor Services Action Plan are to improve 

awareness of the sanctuary and ocean issues, and to provide an enriched and extended coastal 

travel experience. This action plan supports an update of the OCNMS website and use of 

additional appropriate technologies, such as social networking, webcasts, and smartphone 

applications. 

Comment: NOAA should develop a southern information center in Aberdeen. 

Response: The Visitor Services Action Plan outlines efforts to assess locations for additional 

visitor information centers. Planning efforts proposed under this action plan will include 

market feasibility, assessment of potential visitor traffic, and a survey of education and

interpretation thematic opportunities. 

MILITARY ACTIVITIES IN THE SANCTUARY

Comment: The U.S. Navy is committed to considering the use of biodegradable components for 

military expendable materials during training and RDT&E activities to the extent that such 

materials are available, will meet mission requirements, and are practicable. 

Response: NOAA appreciates the U.S. Navy‟s efforts in this area. NOAA has agreed to 

participate in a U.S. Navy-led initiative to develop biodegradable alternatives for expendable 

materials used in marine environments. 
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Comment: No summary of Navy research, development, testing and evaluation, and fleet 

training activities is provided in the document, and NOAA does not set out any position on the 

activities of the U.S. Navy.

Response: The Navy EISs for the Northwest Training Range Complex and the Keyport 

Range Complex Extension were under development simultaneously with the OCNMS 

DMP/DEA. Both Navy EIS documents were finalized in 2010 and they provide the most 

detailed information publically available on Navy activities and their impacts on resources in 

the sanctuary. NOAA does not have additional information on Navy activities in the 

sanctuary beyond what has been presented to the public in these documents. The 

characterization of Navy activities in the sanctuary was expanded in the OCNMS FMP/EA, 

and references were updated. In addition, the issues that NOAA raised with the Navy, 

primarily focused on potential impacts to biogenic seafloor habitats and discharge of 

expendable materials, were noted in the FMP/EA. NOAA supports the mission of the U.S. 

Navy and understands the importance of their research and training activities. NOAA 

believes that, when possible, it is preferable that these activities take place outside of national 

marine sanctuaries. In cases where this is not feasible, NOAA seeks to work with the Navy 

to ensure that their activities are carried out in a manner that avoids to the maximum extent 

practicable any adverse impacts on sanctuary resources and qualities.

Comment: Section 6.4.5 of the EA should explain that the proposed action evaluated in the EIS 

for the Northwest Training Range Complex (NWTRC) did not trigger the consultation 

requirements of Section 304(d) of the National Marine Sanctuaries Act. 

Response: NOAA recognizes that the Navy prepared a detailed Environmental Impact 

Statement (EIS) addressing its activities within the NWTRC, and during the process to 

develop this EIS, the Navy responded to written comments submitted by NOAA. 

Section 304(d) of the National Marine Sanctuaries Act (NMSA) requires federal agencies 

whose actions are “likely to destroy, cause the loss of, or injure a sanctuary resource” to 

consult with NOAA before taking action. NOAA found that the Navy‟s proposed activities 

within the NWTRC increased in scope and intensity the activities previously undertaken by 

the Navy and represented increased adverse impacts to sanctuary resources. NOAA 

recognizes that despite differing opinions of the applicability of section 304 (d), the Navy has 

been willing to meet with NOAA to discuss the effects of Navy activities on sanctuary 

resources, and has responded in writing to reasonable and prudent alternatives recommended 

by NOAA. 

Comment: NOAA should express concern regarding the significant expansion of activities of 

the U.S. Navy in the sanctuary in order to fulfill its public trust responsibilities. 

Response: Both the Navy and NOAA have public trust duties to public resources. NOAA 

commented on the Navy EISs through interagency consultation. Throughout development of 

the Navy‟s documents NOAA worked with the Navy to ensure the protection of sanctuary 

resources. NOAA recognizes the Navy„s cooperation during consultation with NOAA 
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pursuant to section 304(d) of the NMSA on the Navy‟s proposed expansion of the Keyport 

Range Complex.

Comment: The rule should be amended to reflect the fact that authorized Navy activities occur 

in all of the areas described in the Navy‟s comment letter as authorized by 15 CFR 922.152(d).

Response: 15 CFR 922.152(d) references geographically specific areas and identifies a suite 

of Department of Defense activities that are exempt from sanctuary regulations. These 

exceptions do not apply to the entire sanctuary. If the Department of Defense has a need to 

extend the geographic extent of these exceptions or wishes to add new activities to the 

identified list in the regulations, NOAA would consider such changes per the provisions in 

15 CFR 922.152(d)(1)(ii).

ACOUSTICS

Comment: The EA's conclusion that there would be a very low likelihood of adverse effects to 

marine life from use of the common echo sounder does not reflect the best available science. 

Response: NOAA reassessed its analysis, corrected inaccuracies, and provided additional 

information in the FMP/EA. Whereas sound produced by hydrographic survey equipment is 

detectable by some marine mammals, NOAA concluded there is very low likelihood of 

adverse effects to marine life from use of this equipment based on the low intensity level and 

rapid attenuation of the sounds, limited area of sonification, and use of frequencies that are 

beyond peak hearing ranges for most marine mammals.

Comment: The EA, in particular Table 17, which does not identify its source of data, does not 

agree with the best scientific data available in Southall et al. 2007. 

Response: NOAA reassessed its analysis, corrected inaccuracies, and provided additional 

information in the FMP/EA. Southall et al. (2007) does not provide hearing range limits for 

individual species but combines cetaceans into three functional hearing groups: lowfrequency, mid-frequency, and high-frequency cetaceans. The revised EA incorporates 

analysis based on functional hearing groups identified in Southall et al. (2007) and does not 

include Table 17 or statements on the hearing ranges of individual species.

OVERFLIGHT REGULATION

Comment: Any mandate or requirement on overflights must be enacted by the FAA following 

the standard rulemaking process.

Response: The existing overflight regulation for OCNMS has been in place since the 

sanctuary‟s creation in 1994. NOAA is not making any changes to the overflight regulation 

in the rulemaking associated with the OCNMS FMP/EA. The purpose of the overflight 

restriction zone is to minimize disturbance to wildlife from low flying aircraft. Conservation 

of wildlife populations is within the authorities of the NMSA. This regulation is consistent 

with the FAA Advisory that applies to Department of the Interior lands on the outer coast of 
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Washington, but it is not redundant with any FAA regulation. There is a separate rulemaking 

associated with West Coast sanctuaries overflight regulations (75 FR 76319) that was 

developed by NOAA in collaboration with the FAA. NOAA has worked with the FAA to 

ensure that the West Coast sanctuaries regulations are consistent with FAA regulations and 

can be included on FAA aeronautical charts. FAA has supported this effort. 

Comment: The Olympic National Park (ONP) should be afforded the same exemption to the 

overflight regulation that is afforded to local Indian tribes. 

Response: The current exception in 15 CFR 922.152(a)(6) was placed in the original 1994 

OCNMS regulations at the request of the Indian Tribes adjacent to the sanctuary to ensure 

that the Indian Tribes have access to reservation lands. The overflight regulation does not 

prevent staff of the Olympic National Park to access park land; therefore, NOAA does not 

believe that an exception for the ONP is necessary. It is important to note that the OCNMS 

overflight restriction zone does not apply to activities necessary to respond to emergencies 

threatening life, property or the environment (15 CFR 922.152(b)) or to activities necessary 

for valid law enforcement purposes (15 CFR 922.152(c)).

VESSEL DISCHARGE REGULATION

Comment: Cruise ship discharges should be banned in OCNMS, as proposed under 

alternative B.

Response: NOAA has selected alternative B as the preferred alternative, which includes a 

ban on cruise ship discharges, but has modified its analysis in the FMP/EA based upon 

comments received. 

Comment: The proposed regulation unfairly targets cruise ships and not other large vessels. 

Response: Cruise ships are a unique class of vessels that generate wastewater effluents in 

very large volumes and types that are unique in the maritime industry. There is widespread 

precedent for discharge regulation of cruise ships as a distinct vessel class on the West Coast 

of the U.S. (i.e., states of California, Washington, and Alaska) and nationally (i.e., in the 

Environmental Protection Agency Vessel General Permit). 

Comment: NOAA should select the vessel discharge regulation proposed under alternative C, 

which extended the discharge ban to all large vessels traveling through OCNMS.

Response: Alternative C considered a broader prohibition of discharges from additional 

vessel classes. While a discharge ban on all large vessels would reduce the volume of 

wastewater discharged to the sanctuary and would avoid singling out one industry (i.e., cruise 

ships) for regulation, alternative C was not selected as the preferred alternative for addressing 

vessel discharges because vessels other than cruise ships generate a significantly smaller 

effluent discharge volume in comparison to cruise ships. Cruise ships carry numerous 

passengers, whereas most other large vessels traversing or working in the sanctuary have few 

passengers, if any, and small crews. Additionally, there are specific, non-regulatory actions 
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proposed in the actions plans that would address discharges from other types of vessels. 

NOAA plans to continue to assess potential impacts of vessel discharges and will reevaluate 

OCNMS regulations during the next review of its management plan and regulations, or 

sooner if significant issues associated with vessel discharges are identified.

Comment: The analysis of effects of cruise ship discharge on the sanctuary environment that is 

provided in the draft EA and proposed rule is inadequate, inaccurate and overlooks several major 

issues related to dilution, the use of Advanced Wastewater Treatment Systems (AWTS), and the 

level of current research available on the environmental impacts of cruise ship discharges. 

Response: NOAA corrected inaccuracies and revised the analysis of cruise ship discharges 

to incorporate additional information and research findings in the EA. Changes were also 

incorporated into the preamble to the final rule but NOAA has retained the cruise ship 

discharge prohibition in the final rule. NOAA agrees that properly functioning AWTS 

produce effluent with lower contaminant loads than effluent from traditional marine 

sanitation devices (MSDs). NOAA‟s analysis revealed, however, that AWTS are not always 

functioning properly and are not consistently used on cruise ships where they are installed. 

NOAA contends that the most effective protection for water quality in the sanctuary is 

achieved through the cruise ship discharge prohibition included in the proposed rule. 

Analysis in the EA indicates that this prohibition has a negligible effect on the industry, 

given the average transit time of 1.2 hours through the sanctuary and current industry 

practice to avoid discharges into sanctuary waters. 

Comment: The proposed rule is inconsistent with Executive Order 13563 because the 

cost/benefit analysis of the proposed cruise ship discharge regulation is inadequate. 

Response: In the FMP/EA, NOAA modified the analysis of environmental and 

socioeconomic impacts and costs of the proposed ban on cruise ship discharges in OCNMS. 

There is essentially no operational cost to the industry from the implementation of this 

regulation. The regulation generates the benefits of regulatory clarity, regulatory consistency 

among marine sanctuaries on the west coast, and a more precautionary management 

approach to a marine protected area of national significance. The regulation is consistent 

with Executive Order 13563.

Comment: The qualifier "clean" as defined in section 922.151 effectively establishes an 

unattainable "non-detect limit" for any constituent discharged by a cruise ship. 

Response: NOAA agrees that the term “clean” needs to be better explained and has therefore 

added a definition of “harmful matter” in the final rule. The definition of “harmful matter” is 

consistent with the definitions used at other national marine sanctuaries. NOAA believes that 

this additional clarification addresses the concern regarding the feasibility of the proposed 

regulation.

Comment: NOAA should consider an approach that provides for black water and gray water 

discharges that are treated to levels that are scientifically acceptable. 
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Response: Establishment of performance standards for cruise ship discharges in OCNMS 

would create an impractical level of regulatory and enforcement complexity applying to a 

minor portion of the vessels‟ operating area. For example, performance standards, in the 

form of effluent limitations, have been established by the state of Alaska. Alaska regulations 

allow discharge only from AWTS, not traditional MSDs, and include differing limits 

(maximum values for a variety of effluent parameters) based on the type (manufacturer) of 

AWTS and operation of the vessel (in transit > knots or not). These regulations also define 

differing sampling/analysis frequencies for various parameters. Because cruise ships have an 

average transit time of 1.2 hours in OCNMS, performance standards for discharges to 

sanctuary waters are not warranted. The EPA and the state of Washington set water quality 

standards that apply to sanctuary waters within the state‟s waters. However, there are 

currently no standards that apply to sanctuary waters beyond 3 miles which are federal 

waters. 

Comment: NOAA should make sure that this regulation, including the definition of cruise ship, 

is consistent with other regulations, including the EPA‟s Vessel General Permit.

Response: National marine sanctuaries are marine protected areas of national significance 

and often have regulations that are more restrictive than other areas. This is consistent with 

the mandate of the NMSA. The FMP/EA identifies a complex set of international, federal, 

and state vessel discharge regulations with inconsistent requirements that differ based on 

various factors, including country of registration, wastewater stream, treatment systems used, 

monitoring implemented, operation of the vessel, and location of the discharge. Various 

definitions for cruise ship are used in federal and state regulations. The EPA in the Vessel 

General Permit (VGP) provides definitions for medium cruise ships (authorized to carry 

100 to 499 people for hire) and large cruise ships (authorized to carry 500 people or more for 

hire). VGP provisions cover only portions of the sanctuary within 3 miles from shore. 

U.S. Coast Guard regulates cruise ships as passenger vessels over 100 gross tons, carrying 

more than 12 passengers for hire, making a voyage lasting more than 24 hours. Given the 

inconsistency among the various definitions, NOAA will continue to use the definition of 

cruise ships established in the regulations of the four national marine sanctuaries off the coast 

of California. 

Comment: The description of allowed discharges in the proposed cruise ship discharge 

regulation does not account for all non-discretionary discharges, which ban discharges that 

cannot be terminated from vessels (e.g. leachate from anti-fouling hull coatings, cathodic 

protection, etc.).

Response: The cruise ship discharge regulation does not prohibit leachate from anti-fouling 

hull coatings or discharges from cathodic protection. Anti-fouling hull coatings are regulated 

as pesticides by the EPA. NOAA considers such leachates to be water generated by routine 

vessel operations, and as such they are an allowable discharge in OCNMS regulations 

(922.152(a)(2)(i)(C)).
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Comment: NOAA should not prohibit discharging or depositing material from beyond the 

boundary of the sanctuary that subsequently enters the sanctuary and injures a sanctuary resource 

or quality. 

Response: Activities taking place beyond sanctuary boundaries are subject to this regulation 

only if the discharge injures a sanctuary resource or quality within the sanctuary. This is not 

a new regulation and has been in place since 1994.

Comment: NOAA should stay abreast to the routes of cruise ships and if an area of the 

sanctuary is scheduled to receive an immense amount of traffic, NOAA should intervene and 

attempt to redirect the routes.

Response: NOAA is aware of cruise ship traffic patterns within the sanctuary and monitors it 

routinely through the Area To Be Avoided (ATBA) compliance monitoring. Assuming that 

cruise ships continue their high rate of compliance with the voluntary ATBA, cruise ship 

routes will remain well offshore where deep and dynamic marine waters will mitigate 

impacts of discharges. As they transit through the northern waters of the sanctuary at the 

western entrance to the Strait of Juan de Fuca, cruise ships follow established vessel traffic 

lanes that are designed to facilitate safe passage of large commercial vessels. NOAA will 

continue to monitor cruise ship traffic patterns, to evaluate practices, and to assess impacts on 

the environment. 

CULTURAL AND HISTORICAL RESOURCES

Comment: NOAA should commit to a programmatic agreement (PA) to address Section 106 of 

the NHPA compliance in the management plan. 

Response: NOAA has committed to developing a programmatic agreement in the FMP 

(Maritime Heritage Action Plan; Strategy MH1: Cultural Resource Conservation; Activity 

C). NOAA agrees that the components identified in the comment should be incorporated 

into this programmatic agreement. NOAA has met requirements under Section 106 to ensure 

that its FMP is in compliance with the National Historic Preservation Act.

Comment: The protection of cultural resources needs to be incorporated into oil spill response 

planning, training and GRPs. 

Response: These issues are addressed within the context of the Northwest Regional 

Response Team and the Northwest Area Contingency Plan. NOAA supports consideration 

of additional approaches to ensure the protection of cultural resources during oil spill 

response, planning and geographic response plans.

Comment: NOAA needs to assure that cultural resources data is conveyed to the Washington 

State Department of Archaeology and Historic Preservation (DAHP) and other consulting tribal 

governments in a format that is compatible with DAHP GIS standards. 
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Response: NOAA concurs and has edited Maritime Heritage Action Plan, Strategy MH1: 

Cultural Resource Conservation, Activity B to address the need to develop uniform 

guidelines/protocols for cultural resource data collection and sharing. 

TREATY TRUST RESPONSIBILITY

Comment: NOAA should develop work protocols for government-to-government consultation.

Response: While general tribal consultation procedures are documented in section 2.4 of the 

FMP/EA, NOAA also looks forward to working with individual Coastal Treaty Tribes to 

develop more specific, individually defined tribal consultation procedures beyond those 

outlined in the FMP. To support this effort, NOAA added an activity under the Collaborative 

and Coordinated Sanctuary Management Action Plan, Strategy CCM2: Coastal Treaty 

Tribes.

Comment: The DMP section on Treaty Trust Responsibility is too heavily focused on treaty 

rights and the protection of natural resources co-managed by the Tribes and the United States, at 

the expense of other important tribal interests.

Response: Section 2 focuses on treaty rights and NOAA‟s fulfillment of U.S. treaty 

obligations within its statutory mandate and as recommended by the Olympic Coast 

Intergovernmental Policy Council and OCNMS Advisory Council. This chapter was based 

on substantial work by members from the four Coastal Treaty Tribes and NOAA. Thus, 

NOAA did not alter the focus or scope of this chapter because specific guidance was not 

provided by the Coastal Treaty Tribes.

Comment: The regulation requiring consultation with the tribes should formalize the comanagement status of the coast tribes. The Makah Tribal Council proposes that 922.154 be 

modified.

Response: NOAA recognizes our responsibilities to consult with each Coastal Treaty Tribe 

on a government-to-government basis. This responsibility is documented in several places in 

the OCNMS FMP and exists regardless of language in OCNMS regulations. Editing the 

regulations would not substantively change the requirement to consult. NOAA did not 

modify this clause in OCNMS regulations.

Comment: When a Coastal Treaty Tribe is involved in a project permitted by another agency, 

NOAA should be required to consider its fiduciary obligations when deciding whether and how 

to object or condition that project. The Makah Tribal Council proposes that 922.152 (g) be 

modified. 

Response: NOAA did not propose changes to this provision in the January 2011 proposed 

rulemaking; therefore, a separate rulemaking process would be required to modify this 

section of OCNMS regulations. Because case law supports the protection of treaty rights and 

resources when a federal agency is issuing or authorizing permits, as a matter of policy, 

NOAA will consider and respond to a tribal government‟s recommendations when evaluating 
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APPENDIX L – RESPONSES TO COMMENTS

permit authorizations. NOAA will consider this change during a future review of 

regulations. 

PERMITTING 

Comment: Requiring a tribe to be an applicant for a permit from NOAA does not adequately 

reflect its sovereign status.

Response: NOAA does not agree that the requirement to apply for a permit to conduct a 

prohibited activity does not adequately reflect the sovereign status of an American Indian 

Tribe. All governmental entities and agencies, federal, state and tribal, are required to obtain 

a permit to conduct an activity within the sanctuary that would otherwise be prohibited. 

NOAA issues permits to the sanctuary superintendent to conduct research and other activities 

that involve prohibited activities such as seafloor disturbance or anchoring. Being an 

applicant for a permit does not reflect upon the sovereignty of a tribal government and does 

in fact reflect an equal footing with federal and state agencies including NOAA. It is also 

important to note that 15 C.F.R. 922.152 (f) specifically recognizes that the prohibited 

activities in sanctuary regulations do not apply to the exercise of treaty-secured rights.

Comment: Requiring a tribe to be the sole applicant for a sanctuary permit would effectively 

eliminate projects that require partners with technical expertise and greater financial resources. 

Response: NOAA agrees that language in the preamble to the proposed rule created the 

inappropriate impression that a tribe had to be the sole applicant for a permit in this category. 

For the final rule, preamble language was edited to reflect that a permit can be issued to a 

designated representative of a tribe or with a tribe as the sole applicant or a co-applicant. In 

addition, NOAA expanded the list of activities eligible for this permit category to include 

those proposed by the Makah Tribal Council. 

Comment: The need for the proposed change to the tribal welfare provision of the sanctuary 

regulations is not adequately explained. The FMP/EA should address the Makah Bay wave 

energy project or recognize that the coast tribes may prefer jointly sponsored projects that require 

resources from outside the tribes. 

Response: NOAA has modified the preamble to the final rule to more clearly reflect the 

basis for this regulatory change, a concern that an entity other than a tribal government could 

apply for a tribal welfare permit without an explicit agreement with or participation of the 

American Indian tribe. NOAA also added information regarding the Makah Bay wave 

energy project in Section 6.4.4 of the EA.


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