Hello, Members of Council...
Hello, Executive Louws...
...It's me again.
One key argument made by opponents of the Reconveyance is that this decision is not really about water quality.
As a supporter of the Reconveyance, it should come as no surprise to any of you that I dissent from this view.
And so today, I'm pushing back on that argument. Firmly.
At the Reconveyance hearing, many of the opponents referred to statements made by Steve Hood of the Department of Ecology, in reference to the Reconveyance.
Mr Hood's statements were used as a foundation for an argument that the Reconveyance wouldn't have any better impact on water quality in the Lake Whatcom watershed than if the land continued to remain active commercial forest land under the DNR, because it is the opinion of Ecology that forest practices are adequate to protect water quality.
And by that virtue, the opponents dismissed the arguments about water quality with a simple rhetorical wave of the hand.
Allow me to retort.
You see... regardless what Mr Hood might have said... the Department of Ecology has not taken any official position for or against the Reconveyance in specific.
On the other hand, the Department of Ecology has taken a position on the matter of current forest practices and how it relates to current water quality in general.
And that position is...
Ecology has concluded the forest practices and adaptive management programs have not fully met the expectations of research and program performance that underlie the basis for providing the CWA assurances. The adaptive management program has not provided the information needed to validate the effectiveness of the rules in protecting water quality. In fact, no field studies or assessments have been completed that test the ability of the rules to meet state water quality standards.
The statement above is taken from page 4 of a document published by Ecology on July 15, 2009, titled 2009 Clean Water Act Assurances Review of Washington’s Forest Practices Program.
http://www.ecy.wa.gov/programs/wq/nonpoint/ForestPractices/CWAassurances-FinalRevPaper071509-W97.pdf
I have included a link to this document and as a citizen who is interested in the Reconveyance, I request that this document be included in the packet of materials that Council and County Staff rely upon to determine what is to be done regarding the Reconveyance.
This 29-page report is written in language that is within the comprehension of any citizen willing to participate in this process, and does not require any specialized knowledge of engineering or forestry to understand.
The document is written as diplomatically as possible, and carries an optimistic tone about the long term prospects of forest practices and water quality. Nonetheless, it is clear that the Department of Ecology does not give a ringing endorsement to contemporary forest practices in Washington State in terms of the impact of those practices on water quality right now.
I strongly suggest that any findings of fact adopted by the County Council regarding the impact of forest practices on water quality include an accurate reference to the official position of the Department of Ecology, and that Council resist the temptation to base findings on what someone said they heard Steve Hood say.
Here are a few more excerpts...
From page 3...
After ten years, no studies have been completed or data collected that provide an indication of whether or not the forest practices rules are improving water quality or maintaining forested waters in compliance with the water quality standards.
From page 10...
There are significant problems with the ability of the policy and science arms of the AMP [Adaptive Management Program] to work together to test and revise the rules in a timely and effective manner. Part of the problem is simply inherent in a program that seeks to develop consensus among stakeholders with competing interests. But the problems also seem rooted in the foundation of the AMP itself. AMP participants frequently disagree about the appropriate roles of science and policy, as well as what role the initial negotiated forests and fish rules should play in evaluating the acceptability of future changes. These disagreements appear in part to stem from a lack of clarity in the underlying rules and guidance. Combined with poor communication between the science and policy arms of the program, this is compromising the AMP’s effectiveness.
From page 13...
After almost ten years, no CMER studies have been completed that inform whether or not the forest practices rules can be relied on to bring waters into compliance with the state water quality standards and the CWA.
From page 20...
The state Legislature eliminated the planning requirements for SFL [small forest landowners], making it very difficult to know how well their roads are being maintained in compliance with water quality standards and other resource objectives. DNR was charged by the Legislature with conducting two interim assessments on the status of roads on SFL properties. The first briefing period was in December 2008, but provided no actual direct assessment of the condition, risk, or progress of SFL roads. The second briefing date is December 2013. But if substantial problems exist that are not identified until 2013, there is little chance corrective action can be taken in time to reach the 2016 target for bringing roads into compliance with current management practices.
The opponents of the Reconveyance have insisted that the Department of Ecology officially supports a claim that forest practices actually protect water quality. As it turns out... not so much.
The DoE is not able to support claims regarding current forest practices in Washington State as meeting water quality standards.
The confidence in the DNR and Ecology is particularly ironic when it stems from those who have a well documented history of breathing not a single good word about government at the state level. It is hardly surprising to find out that this confidence is misplaced and based on factual misunderstanding.
So, the question for you is...
...to whom are you going to give the benefit of the doubt?
The opponents of the Reconveyance who have made shrill assertions that are not supported by the facts?
Or the supporters of the Reconveyance, many of whom are water customers who rely on the Lake Whatcom Watershed for safe drinking water?
Remember also that Ecology isn't asking for any benefit of doubt. They are confident that they unable to vouch for forest practices, including the maintenance of logging roads, as protecting water quality. And they are also confident that they will not be able to vouch for those practices... not even in Whatcom County... until at least 2016.
And all due respect to the notion that the Reconveyance is not time sensitive... I'm not willing to wait until 2016.
I am asserting... right now... that the Reconveyance is more likely than not to have a beneficial impact on the quality of my drinking water... right now.
I assert further that... right now... the Reconveyance is more likely than not to reduce the risk to the quality of my drinking water particularly when compared to the risk posed by commercial forest practices... right now.
I base this on my belief that, all other things being equal, the absence of commercial forestry tends to pose less of a risk to water quality than the presence of commercial forestry... right now.
I expect you to err on the side of the safety of my drinking water... right now.
I need the benefit of the doubt on this matter more than the DNR needs it. And I need it right now.
In the absence of evidence... right now... that forest practices are protecting my drinking water... right now... you have a duty to assume that they don't protect my drinking water... right now.
Lake Whatcom is an impaired body of water... right now... and it is incumbent upon you to keep risks to that water body to a minimum... right now.
So, pretty please with sugar on top, protect my drinking water... right now.
Patiently,
Shane Roth
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