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Brief Synopsis and
Observations by Sue Forde After scanning all 33 pages of Exhibit "B" (the Clean Water Strategy for Addressing Fecal Coliform in Dungeness Bay and Watershed), I have been attempting for the better part of the day to get the pages into a format that I can upload as a pdf file - and have not yet been successful. I will try again tomorrow. Meanwhile, allow me to bring out just a few of the points that I believe are cause for concern after quickly looking over the document: (Comments are unashamedly mine, after putting in hours and hours of research on this whole issue over the past two weeks.) 1. Statements are made based on a false premise. The document goes from the mandate of a "Shellfish Protection District", which requires an ordinance, to incorporating the Clean Water District, which has been a baby of the Dungeness River Management Team, Department of Ecology and the Puget Sound Water Quality Action Team for some time. The ideas, as I see it, is to control the entire Dungeness Watershed - which is not necessary. 2. The document states that "as a result of land-use changes"...water quality in both fresh and marine waters has deteriorated. It's only the marine waters at the Bays that fall under the requirement of the state. All the rest is pure rhetoric, and not backed scientifically. 3. The document brings in the federal Clean Water Act's 303(d) list for bacterial contamination of waters. This should not even be mentioned under the "Shellfish Protection District" - it has absolutely nothing to do with commercial shellfish, which is what the state law covers. 4. Under "Water Clean Up Plan", there will be a "monitoring plan" to assess the effectiveness of these efforts. The Strategy states that "Ecology's Water Clean-up Plan will address the Federal law requirement, under the Clean Water Act, which requires States to identify sources of pollution in waters that fail to meet state water quality standards, and to develop Water Clean Up Plans to address those pollutants. So, this "Strategy" actually incorporates several more "Strategies and Plans" and brings in - under the umbrella of this proposed ordinance - the state and federal agencies to further monitor and enforce their own rules. I haven't had time to research this thoroughly (with only 2 days to do anything after receiving this document, in addition to working for a living), but I would guess that without these other Plans being "piggy-backed" into county law underneath this proposed ordinance, there would be no way for them to be enforced. We don't need more layers upon layers of rules, regulations and enforcement! 5. Under "Shellfish Downgrade", it lists that the standards for approved shellfish growing waters is "fecal coliform geometric mean not greater than 14 organisms/100 ml, and an estimate of the 90th percentile not greater than 43 organisms/100ml." To illustrate how small this amount is, an example was given by the state biologist of a pristine pond high in the alpine meadows: it's count was 200-300 organisms/100ml - and there are no people around up there to pollute! 6. Under the "Shellfish Downgrade Requirements", the document states that "this plan builds on the previous document, Dungeness Bay Shellfish Closure Prevention Response Strategy, developed in 1997 and 1998, as well as the Dungeness Bay Watershed Management Plan (adopted in 1994). I was able to locate a little something on the latter (click here), and noticed that "nonpoint source pollution" has been addressed since 1991. I haven't seen the total documents on either of these, so can't relate what might be in them and how much power they give to the various agencies and tribes over private land. 7. The document states that this Strategy addresses fecal coliform in the "freshwater ditches, stream and river" that flow into the marine waters of Dungeness Bay, as well as the bay itself. There is no need to encompass such a broad area. Perhaps a look a Dabob Bay would help: the finding there was that the fecal coliform problem was primarily caused by seals. There are plenty of seals at both Dungeness Bay and Sequim Bay; they should be looked at first for the possibility as cause rather than covering the entire watershed, from Bagley Creek to Sequim Bay, and all the way to the mountains. 8. The Strategy states that "on October 11, 2000, a recommendation was made by the Dungeness River Management Team (DRMT) to the Clallam County's Board of Commissioners to call the shellfish protection district a "Clean Water District" and to have its boundaries be the same as the management area of the DRMT. The DRMT management area "includes the Dungeness watershed and those waters influenced by it through the irrigation system, and the Sequim Bay watershed." This is been known about with this "special interest group", or "shadow government" as some are now calling it [the DRMT], and could have been brought to the voters at that time. Instead, they've waited until there's a supposed "crisis", and so the county commissioners will be making that decision for the voters - and creating a taxing district that will probably encompass most of unincorporated Clallam County. 9. "It is anticipated that related strategies will be implemented or developed to address other water quality problems within the proposed Clean Water District. Hi, I'm from the government, and I'm here to help you! Once the nose is under the tent.... I'll continue reading and notating as time permits. Take time to read some of the comments by several of the individuals who testified at the commissioner's hearing. (Bolds and highlights are mine. SF) |