A Factory Ship, Federal Waters, and a Decade of Permits

Starbound, LLC is a Seattle-based corporation that owns and operates a commercial fishing and processing vessel named the Starbound (U.S. Coast Guard Number 944685). The company had legal permission to discharge seafood processing waste into federal waters. That permission came with conditions. Starbound ignored most of them.

• The vessel operated as a floating factory, catching and processing hake off Washington and Oregon, and pollock and Pacific cod off Alaska, all within federal waters regulated under the Clean Water Act.
• The ship had an onboard meal plant that cooked and dried fish residue including skin, bones, and heads, then ground it down. The cooking process generated a gelatinous, high-nutrient liquid byproduct called stickwater, which was discharged directly into the ocean.
• The vessel had 15 discharge points, six of which were equipped with grinder pumps designed to reduce solid waste to half an inch or smaller before release. That means the ship was built to dump waste at industrial scale.
• The EPA, which directly administers the NPDES permitting program for offshore seafood processors in the Pacific, issued the relevant permits: the Washington and Oregon Permit (effective May 1, 2019, Permit No. WAG520000) and the Alaska Permit (originally effective March 1, 2010, reissued July 17, 2019, Permit No. AKG524000, and modified June 2, 2021).
• Starbound filed Notices of Intent (NOIs) to operate under these permits and self-declared the maximum volumes of waste it expected to discharge. Those self-declared numbers became the legal ceiling. Starbound blew through them.

14 Violations. Years of Silence. All Documented.

The EPA’s consent agreement lists fourteen discrete violations spanning both the Washington/Oregon Permit and the Alaska Permit, covering 2019 through 2021. Each one represents a specific legal obligation that Starbound agreed to and then discarded.

Violations Under the Washington & Oregon Permit

• Violation 1 — Discharge Exceedances: Starbound self-declared in its Notice of Intent that it would discharge a maximum of 9,240,000 pounds of seafood processing waste residue per year. It discharged 9,343,749 pounds in 2019 and 9,503,552 pounds in 2020, exceeding the cap by 103,749 lbs and 263,552 lbs respectively. The company did this without seeking an amended permit.
• Violation 2 — Failure to Update NOI: When a company exceeds its own declared discharge limits, the permit requires it to immediately file an updated or amended Notice of Intent. Starbound did neither in 2019 or 2020, nor did it include an updated NOI in the required Annual Reports for either year.
• Violation 3 — No Pre-Operational Outfall Check: Before processing begins each season, regulations required Starbound to physically inspect its outfall system to confirm waste is being discharged at or below the sea surface, and to log that inspection. For the 2021 processing season, no check was performed and no log was kept.
• Violation 4 — Missing Discharge Photos: The permit required at minimum four photographs per quarter of each outfall discharge point while processing occurs, each labeled with date, time, photographer name, and description. Starbound failed to take these photos during the entirety of Quarter 4, 2021.
• Violation 5 — No Water Sampling: Representative water quality samples of discharge and stickwater were required quarterly and annually. Starbound failed to collect or analyze samples for Quarter 2 of 2020, and Quarters 2, 3, and 4 of 2021, and failed to collect any annual stickwater sample at all in 2021.
• Violation 6 — Late and Missing Discharge Monitoring Reports (DMRs): Quarterly electronic DMR filings were due on fixed deadlines (May 20, Aug 20, Nov 20, Feb 20). Starbound filed late for Q3 and Q4 of 2019; Q1, Q3, and Q4 of 2020; and Q1 of 2021. It failed to file at all for Q2 of 2020, and Q2, Q3, and Q4 of 2021, effectively going completely dark for three consecutive quarters.
• Violation 7 — Late Annual Reports, Multiple Agencies: Annual reports were due February 14 each year to EPA, the Washington Department of Ecology, the Oregon Department of Environmental Quality, and, when operating in designated areas, the Olympic Coast National Marine Sanctuary, the Quileute Indian Tribe, and the Quinault Indian Nation. Starbound submitted the 2020 Annual Report to EPA in December 2021. It submitted 2019 and 2020 reports to Oregon DEQ in December 2021 and to Washington Ecology in August 2022. The 2019 Annual Report reached the Olympic Coast National Marine Sanctuary in August 2022, nearly two and a half years late. Reports to the Quileute and Quinault Nations also arrived in August 2022.
• Violation 8 — No Noncompliance Disclosure: Annual reports must include a summary of any noncompliance: what happened, why, what was done to fix it, and how it would be prevented in the future. The 2019 and 2020 Annual Reports contained none of this.
• Violation 9 — Incomplete Production Data: Annual reports were required to show monthly maximum daily discharge totals, monthly stickwater volumes, and atmospheric water vapor losses during secondary byproduct production. Starbound omitted the maximum daily discharge data from both the 2019 and 2020 reports, omitted monthly stickwater quantities from the 2019, 2020, and 2021 reports, and omitted the atmospheric water vapor data from the 2021 report.
• Violation 10 — Missing Vessel Location Data: The permit required Starbound to include in each Annual Report at least one GPS location per day for every day the vessel was discharging. Starbound failed to provide discharge location data for September 30, 2021 in the 2021 Annual Report.
• Violation 11 — No Distance Travel Data: The permit required the company to report the minimum and average daily distance the vessel traveled during each month of active discharge. This data was entirely absent from the 2021 Annual Report.

Violations Under the Alaska Permit

• Violation 12 — Late Alaska Annual Reports: Starbound was required to submit complete, accurate annual reports to EPA by February 14 each year. The 2019 and 2020 Alaska Annual Reports were submitted on August 22, 2022, years past deadline.
• Violation 13 — No Alaska Quarterly Photo: The Alaska permit required at least one photograph per quarter of the discharge’s receiving water, any waste visible on the sea surface, interactions with seabirds or marine mammals, and the size of waste particles. Starbound was confirmed processing during Q2 of 2021 and failed to take a single required photograph.
• Violation 14 — Missing Alaska Stickwater Data: Monthly stickwater discharge quantities were required in the Alaska Annual Report. Starbound omitted them entirely from the 2021 Alaska Annual Report.

The Timeline: How Long Starbound Was Allowed to Operate Without Accountability

The gap between when violations began and when any penalty was assessed spans more than five years. That gap is the story.

The Non-Financial Ledger: What Money Cannot Measure

The federal waters off the coasts of Washington, Oregon, and Alaska are among the most biologically productive ocean zones on earth. They are not abstractions on a legal document. They are the food chain. They are the livelihood. They are the sacred grounds of peoples who have fished these waters for thousands of years.

Starbound operated inside the boundaries of the Olympic Coast National Marine Sanctuary. The Sanctuary exists precisely because those waters are fragile and irreplaceable: humpback whales feed there, sea otters nest there, seabird colonies depend on the abundance of small fish in those currents. When a factory vessel dumps millions of pounds of organic industrial waste into that ecosystem without proper documentation or oversight, no one on shore gets to know, because the company didn’t file the paperwork to tell them. That is the point. The monitoring requirements, the quarterly photographs, the water samples, the location logs — those are not bureaucratic inconveniences. They are the only mechanism by which anyone outside the vessel can verify what is happening in a protected ocean zone.

The Quileute Indian Tribe and the Quinault Indian Nation have treaty-recognized usual and accustomed fishing areas in these same waters. Their right to know what industrial actors are discharging into their ancestral fishing grounds is not a courtesy. It is a legal obligation. Starbound had annual report disclosure requirements to both nations, and those reports arrived in August 2022, years after they were due. For at least three reporting cycles, these communities were denied information they were legally entitled to about commercial industrial activity occurring directly inside their traditional territory. They could not evaluate contamination risks. They could not raise regulatory objections in time. They were simply kept in the dark while a commercial vessel processed millions of pounds of fish and pumped the waste into their waters.

There is no line item in the $168,000 penalty for that. There is no line item for the unknowable question of what went into the water during the quarters Starbound went completely silent — no water samples collected, no discharge monitoring reports filed, no photographs taken. The regulatory record for Q2, Q3, and Q4 of 2021 is a black hole. The vessel was out there processing. The company has confirmed this. What was discharged, at what volumes, at what locations, and in what condition — that data simply does not exist because Starbound chose not to create it.

The penalty treats each of these failures as a financial transaction to be settled. The ecosystem and the communities whose sovereignty was disrespected do not receive a settlement. They receive silence, and then the vessel goes back out to sea.

In Their Own Words: What the Documents Actually Say

Every quote below is lifted verbatim from the EPA Consent Agreement, Docket No. CWA-10-2024-0105. No paraphrase. No editorializing. This is the official government record.

“EPA alleges Respondent violated Section V.A.3 of the Washington and Oregon Permit by exceeding the annual weight of seafood processing waste residue listed on their NOI (9,240,000 pounds) twice: 9,343,749 pounds in 2019 and 9,503,552 pounds in 2020.”
— Consent Agreement, Part III, ¶3.22

• This confirms the core violation: Starbound exceeded its own declared legal ceiling in consecutive years, and the volume of excess increased from year one to year two, suggesting the problem was worsening rather than being corrected.
• The company’s self-declared NOI limit was the only line of accountability. When they blew past it and said nothing, the entire permit framework broke down.

“EPA alleges that Respondent violated Sections IV.A.3 and VI.B.4.d of the Washington and Oregon Permit by failing to submit an updated NOI and failing to include the updated NOI in the Annual Report when the annual weight of seafood processing waste residue discharge exceeded the authorized levels in 2019 and 2020.”
— Consent Agreement, Part III, ¶3.25

• This is not a paperwork technicality. The NOI update requirement exists so that the EPA can evaluate whether higher discharge volumes are environmentally acceptable before they happen. Starbound bypassed that evaluation entirely, both years.

“EPA alleges Respondent violated Sections V.B.7.c and VIII.B.a of the Washington and Oregon Permit by failing to submit quarterly DMRs at all for Quarter 2 of 2020 and for Quarter 2, Quarter 3, and Quarter 4 of 2021.”
— Consent Agreement, Part III, ¶3.37

• Three consecutive quarters of zero reporting in 2021 means there is no regulatory record of what Starbound discharged into federal waters during the majority of that year. This is a complete monitoring blackout during active operations.
• The EPA could not have caught this in real time because the reporting system depends on the company filing the reports. When the company stops filing, the regulator is blind.

“EPA alleges that Respondent operated within the boundaries of the Quileute Indian Tribe’s and the Quinault Indian Nation’s usual and accustomed fishing area boundaries in 2019 and 2020. EPA alleges that Respondent submitted the 2019 and 2020 Annual Reports to the Quileute Indian Tribe and the Quinault Indian Nation in August of 2022.”
— Consent Agreement, Part III, ¶3.42

• The 2019 Annual Report was due by February 14, 2020. It arrived in August 2022: two years and six months late. The 2020 report, due February 14, 2021, arrived eighteen months late.
• Both tribal nations hold treaty fishing rights in these waters. The delayed disclosures mean those governments had no access to Starbound’s discharge data when it would have been actionable.

“Respondent neither admits nor denies the specific factual allegations contained in this Consent Agreement.”
— Consent Agreement, Part IV, ¶4.2

• This is a standard legal settlement clause, but its implications are significant: Starbound paid $168,000 and walked away without ever officially acknowledging that any of the 14 violations occurred. There is no binding admission on the record.
• Future regulators evaluating Starbound’s “prior history of violations” will find a settlement with no admission, which weakens the precedent the case creates.

“After considering all of these factors as they apply to this case, EPA has determined that an appropriate penalty to settle this action is $168,000.”
— Consent Agreement, Part IV, ¶4.3

• The statutory maximum for these violations ran up to $26,685 per day per violation, with a cap of $333,552 per violation, under the 2024 inflation-adjusted penalty schedule. The $168,000 total settlement covers 14 violations spanning three years.
• EPA cited Starbound’s ability to pay, degree of culpability, and economic benefit from non-compliance as factors in the calculation. The specific economic benefit Starbound derived from these violations was not disclosed in the public document.

Societal Impact Mapping: Who Bears the Cost When a Corporation Skips Accountability

Environmental Degradation

The documented violations involve years of unmonitored industrial discharge into some of the Pacific Coast’s most ecologically sensitive federal waters, including a designated National Marine Sanctuary.

• Stickwater, the gelatinous high-nutrient cooking byproduct discharged from Starbound’s meal plant, contains proteins, oils, and suspended organic solids. Excess stickwater discharge in concentrated ocean zones can trigger localized hypoxic conditions, depleting dissolved oxygen and stressing marine life including the very fish species the vessel was commercially harvesting.
• Starbound operated inside the Olympic Coast National Marine Sanctuary in 2019 and withheld the legally required annual report from Sanctuary managers until August 2022, meaning the Sanctuary had no documented record of the vessel’s discharge activities for over two years after they occurred.
• The vessel had 15 active discharge points, six equipped with grinders, meaning solid fish waste was being ground to half an inch or smaller and released continuously during processing operations. For the quarters when no photographs, no water samples, and no DMRs were filed, the composition and volume of that discharge is unknown and unverifiable.
• The absence of location data for September 30, 2021, and the absence of daily distance travel data for the entire 2021 season means regulators cannot confirm which specific ocean zones received Starbound’s discharge during that period, including whether sensitive habitat zones were affected.
• No remediation or habitat restoration requirement appears anywhere in the Consent Agreement. The penalty is purely financial. The ecosystem received nothing.

Economic Inequality and Indigenous Sovereignty

The communities with the highest stake in water quality and fishing stock health in these federal waters — federally recognized Indigenous nations with treaty-protected fishing rights — were among the last to receive any information about Starbound’s discharge operations.

• The Quileute Indian Tribe and Quinault Indian Nation hold treaty-recognized usual and accustomed fishing rights in the same federal waters where the Starbound vessel operated and discharged industrial waste. These are rights recognized by the U.S. federal government and enforceable in federal court.
• Starbound’s 2019 and 2020 Annual Reports reached both tribal nations in August 2022. The 2019 report was due February 14, 2020: it arrived approximately 30 months late. The 2020 report was due February 14, 2021: it arrived approximately 18 months late.
• During those 18 to 30 months of delayed disclosure, neither tribal government could evaluate whether Starbound’s discharge was affecting the fishing stocks and water quality in their ancestral territory, whether to request regulatory intervention, or whether to notify tribal members of potential contamination concerns.
• The $168,000 penalty contains no component directed to either tribal nation. There is no provision for consultation, no mandated outreach, and no acknowledgment of the specific harm caused by the delayed tribal disclosures beyond listing it as one violation among many.
• Starbound LLC is a private commercial corporation operating for profit in waters where Indigenous peoples have subsistence and treaty fishing rights. The regulatory framework that was supposed to protect those rights relied entirely on Starbound’s voluntary compliance and self-reporting. Starbound did not comply. The federal penalty structure treated the failure as equivalent to any other paperwork deficiency.

Public Health

The failure to collect mandated water samples during active processing operations means there is no scientific record of what was actually discharged into these waters or at what concentrations during the periods Starbound went dark.

• The Clean Water Act’s water quality sampling requirements for offshore seafood processors exist to detect elevated levels of pollutants including biochemical oxygen demand, total suspended solids, oil and grease, and pH deviation, parameters that affect fish tissue quality and ecosystem health in ways that travel up the food chain to human consumers.
• Starbound collected no representative effluent samples for Q2 of 2020 and for Q2, Q3, and Q4 of 2021. It collected no annual stickwater sample in 2021 at all. The water quality data gap for these periods is total; there is no substitute dataset.
• Commercial and tribal fishers operating in the same federal waters during these periods had no access to Starbound’s monitoring data that should have existed and did not, meaning decisions about where to fish and what fish were safe could not account for the actual state of those waters near the Starbound vessel’s operations.

The “Cost of a Violation” Metric: What $168,000 Actually Means

What Now? How to Apply Pressure and Stay Informed

The Consent Agreement names the individuals who signed off on this settlement. Apply pressure through the institutions that still have jurisdiction, because the Final Order explicitly states that criminal sanctions and injunctive relief remain available, and this case closed civil penalties only.

Key Signatories on This Document

• Edward Kowalski, Director, Enforcement and Compliance Assurance Division, EPA Region 10: Signed the Consent Agreement on behalf of the EPA on June 25, 2024. His division negotiated the $168,000 settlement.
• Richard Mednick, Regional Judicial Officer, EPA Region 10: Issued the Final Order on July 25, 2024, ratifying and incorporating the Consent Agreement. The case is now closed at the administrative level.
• Starbound, LLC, 33 U.S.C. § 1362(5) “person,” domiciled Seattle, Washington: The Respondent. Their authorized representative signed the Consent Agreement. The document does not identify the individual signatory by name beyond the corporate role.

Regulatory Watchlist: Bodies That Still Have Jurisdiction

• EPA Region 10 (Seattle): Still holds ongoing compliance authority over Starbound’s NPDES permits. The Final Order explicitly preserves EPA’s right to pursue injunctive relief or criminal sanctions for any violations of law. File public comments and watchdog requests directly with EPA Region 10’s Enforcement and Compliance Assurance Division.
• Washington Department of Ecology: A recipient of Starbound’s required annual reports and a co-regulator of state water quality adjacent to federal waters. File a public records request for all communications between Ecology and Starbound LLC related to NPDES compliance since 2019.
• Oregon Department of Environmental Quality (DEQ): Same standing as Ecology, receiving Starbound’s annual reports covering Oregon coastal operations. DEQ has independent enforcement authority under Oregon law.
• Olympic Coast National Marine Sanctuary (NOAA): Operates within NOAA’s Office of National Marine Sanctuaries. The Sanctuary received Starbound’s 2019 annual report years late and has standing to raise concerns about future permit coverage and operations within Sanctuary boundaries.
• Department of Justice (DOJ): Per the Final Order, Section 4, EPA may request the Attorney General to bring a civil action for unpaid penalties, and criminal sanctions for CWA violations remain available outside this civil settlement. The DOJ Environment and Natural Resources Division handles CWA criminal referrals.
• National Oceanic and Atmospheric Administration (NOAA) Fisheries: Governs commercial fishing license conditions in the same federal waters. Permit conditions and compliance history are relevant to license renewal decisions.

Tribal Sovereignty and Treaty Rights

• The Quileute Tribe and Quinault Indian Nation have treaty-recognized fishing rights and governmental authority in their usual and accustomed areas. Both nations received delayed disclosures. Contact their respective tribal environmental offices directly if you are a tribal member, researcher, or advocate with relevant information about this vessel’s operations.
• Support Indigenous-led environmental monitoring programs in the Pacific Northwest that operate independently of corporate self-reporting frameworks. These organizations conduct on-the-ground water quality and fisheries monitoring that fills the gaps when corporations go dark.

Direct Actions and Organizing

• Submit a formal comment to EPA Region 10 requesting that Starbound LLC’s permit renewal be subject to enhanced monitoring requirements, including third-party verification of discharge data, given the documented pattern of self-reporting failures.
• Request the full case record under the Freedom of Information Act (FOIA) from EPA Region 10. The public consent agreement is 17 pages. Correspondence, inspection records, and internal penalty calculation memos may reveal additional detail about the extent of violations and the EPA’s reasoning for the $168,000 settlement figure.
• Connect with Pacific Coast commercial and tribal fisher organizations who compete for the same fish stocks in the same waters. The monitoring blackouts created by Starbound’s missing DMRs and water samples affect every actor in that ecosystem, not only regulators.
• Support organizations doing legal advocacy for stronger per-violation penalty floors in CWA administrative settlements, so that $168,000 stops being a viable business calculation for three years of documented environmental misconduct by a commercial operator.
• Share this article with your representatives on the Senate Environment and Public Works Committee and the House Transportation and Infrastructure Committee’s Water Resources and Environment Subcommittee, the bodies with direct oversight over EPA enforcement adequacy under the Clean Water Act.