Meeting the Needs of the People

Fish Consumption Rates in the Pacific Northwest

Wendee Nicole


Environ Health Perspect. 2013;121(11) 

In This Article

Oregon's Experience

Although Washington differs in several ways from its southern neighbor—including having a larger population,[29,30] a larger number of federally recognized tribes,[31] more industry,[32] and two coastlines (the Pacific Ocean and Puget Sound) instead of one—WADOE has looked to Oregon to learn from its success: The water quality standards rulemaking process there won Oregon's Department of Environmental Quality (ORDEQ), the EPA, and CTUIR, plus a facilitator, awards from the U.S. Institute for Environmental Conflict Resolution.[33]

"It was rocky in the beginning, and in the end I attribute a lot of the success to the tribe's leadership," says Andrea Matzke, a water quality specialist with ORDEQ. "The three governments [federal, state, and tribal] collaborated, and that was instrumental."

In 2004 Oregon's Environmental Quality Commission had adopted a 17.5-g/day fish consumption rate, as per the EPA's nationwide suggested guideline. "The tribes, particularly, had a lot of concerns and were saying 17.5 doesn't really represent what many of the tribal community eat here, and so they talked a lot with EPA, and [EPA] delayed their approval," explains Matzke.

Considering the real possibility that the EPA might reject its submitted standards, ORDEQ decided to work closely with the tribes and the EPA to develop new standards through a public process.[34] The state came to an agreement with the tribes and the EPA to use a 175-g/day fish consumption rate, which protects up to the 95th percentile of Oregonians who consume the most fish, according to research conducted by the Columbia River Inter-Tribal Fish Commission, the EPA, and tribal biologists.[35,36,37,38,39] The revised human health criteria were approved by the Oregon Environmental Quality Commission in 2011[9] and by the EPA a few months later.[40]

The state also worked with tribes and industry on implementation tools to enable factories and municipalities to comply with the stricter standards. While the tribes made concessions (Carl Merkle, a salmon recovery policy analyst for the CTUIR, says many tribal members wanted an even higher rate than 175 g/day), the result was something all parties could live with. Merkle points out that the state reached the compromise "sometimes at great institutional and political cost." He says, "We benefited from some state officials in Oregon who showed remarkable courage."

"It wasn't a slam dunk. It was really hard work," says Mary Lou Soscia, Columbia River coordinator for EPA Region 10.

Oregon's new rate raised the bar for the region, and the EPA has repeatedly told tribes it would like to see similar rates in Washington and Idaho.[41] Alaskan officials indicated they may soon revise that state's standards, and Idaho is in the process now.

Idaho updated its standards in 2006 using a fish consumption rate of 17.5 g/day, but the EPA did not act to approve or disapprove the standards until 2012, when a lawsuit from environmental groups upped the pressure. At that point "we disapproved the Idaho rate because they hadn't done an adequate review of existing fish consumption data out there," says Soscia. Idaho is back at the drawing board.