Wood chip polluting wildlife refuge!

The Washington state department of ecology has issued a stop work order based on my using wood chips on my farm. The exact charge is "discharging pollutants into the waters of Washington state". You can see my appeal letter here.

You see, they are claiming that by spreading wood chips that I'm affecting water quality.
The problem with this theory is that none of these pictures, of hundreds of cubic yards of wood chips spread up to 5' deep and 12' wide and 1500' long... are taken at my farm. They're taken at the portage creek wildlife refuge, where the folks at the snohomish county parks department inform me that they've spread HUNDREDS of dump truck loads of the stuff since 1992. In fact, they spread more all the time.

there's 7' of wood chips there.

This pile of wood chips is 15' wide, and over 1500' long. It's through the wildlife sanctuary, and it was put down as mulch to suppress the reed canary grass that is the primary vegetation here.

This land is identical in all respects to mine -- but this is a dedicated wildlife preserve. If wood chips are detrimental to water quality, what the heck are HUNDREDS OF DUMP TRUCK LOADS doing in a wildlife preserve?

I called four different wholesalers of wood chips, and have a list of sites where hog fuel has been delivered in large quantities. For something that pollutes the waters, it's used all over the place. I had no idea.