(An editorial recommendation just prior to the Pollution Control Board
hearing)




Disingenuous Pseudo Science


Readers of this column will recall our last two issues. In our May 10
issue we illuminated a situation that could potentially effect all
boaters who rely on boatyards in the Puget Sound region for maintenance
and repair services. An anonymous source, ("Deep Draft"), outlined
some of the frustrations experienced by regional boatyards as the firms
attempt to deal with vaguely defined policies of the EPA under the
NPDES permit. Deep Draft detailed how the Department of Ecology, the
Northwest Marine Trade Association, area boatyards, and the
environmental lobby (represented by Puget Soundkeepers Alliance) met
numerous times to discuss and debate the issue of storm water runoff
from boatyards. Following these discussions and upon considering all
sides, the EPA issued a new NPDES permit to allow boatyards, as a
general class of business, to continue operation. The new permit set
much stricter standards for cleanliness of storm water runoff than
previously existed.

In the June 7 issue, Sue Joerger of Puget Soundkeepers Alliance
explained why her group had filed an appeal to overturn the NPDES
permit. She maintained that the average copper content measured as
storm water discharges from boatyard drainpipes is approximately 2000
parts-per-billion (ppb). Sue additionally stated that the health of
juvenile salmon can be adversely effected if the young fish swim in
water with more than 3 or 4 ppb, a concentration 500 to 700 times more
diluted than the outflow from the typical boatyard drainpipe. Because
the newly issued NPDES permit only required boatyards to reduce copper
content in drainpipe effluent from 2000 ppb to 384 ppb, (rather than 3
or 4 ppb), Puget Soundkeepers Alliance has demanded a hearing, July 10,
at the State Pollution Control Board. According to Sue Joerger, the
goal of Puget Soundkeepers Alliance is to force the EPA to rescind the
permit and reopen discussion of the storm water runoff standards.
Apparently the progress represented by a reduction of copper content in
boatyard runoff pipes from 2000 ppb to 384 ppb is less than
satisfactory to a group that would prefer to see the 2000 ppb number
reduced to virtually zero (3-4 ppb).

After considering both sides of this issue, we would urge the Pollution
Control Hearings Board to reject the appeal of Puget Soundkeepers
Alliance. While "saving Puget Sound" is a noble and worthy cause,
members of the Soundkeepers Alliance either slept through seventh grade
science class or are pursuing an agenda that will be more easily
realized if everyone else did.

The fatal scientific flaw in the Soundkeepers' argument is extremely
basic and glaringly obvious. While boatyards have been required to
sample storm water runoff and submit the samples to be evaluated for
copper content, no other industries or municipalities have been
required to take similar samples! There is no "control" number. We
know that the "typical" boatyard discharges storm water with 2000
ppb, but what we don't know is what the readings would be if the
boatyards didn't exist. While it would seem unlikely, we have no way
to demonstrate that storm water runoff from a Wal Mart parking lot, an
office building or some other non-marine related use might not be even
higher in copper content than the 2000 ppb flushing out of a boatyard
drainpipe. While copper is a common component of bottom paint, nearly
all boatyard operators are almost fanatic about keeping bottom paint,
either fresh from the can or blasted off a hull with a pressure washer,
from getting into the environment. Brake pads on cars and trucks
distribute a dusting of copper on all streets, highways, and parking
lots. Because we have not sampled and evaluated other storm waters, we
have no idea whether the storm drain from a residential street might
not be nearly as high, or even much higher, than the runoff for a
boatyard.

Among storm water runoffs that have not been evaluated, we surely must
include condominium projects. Projects like the group of condo
buildings currently rising along Northlake Avenue in Seattle, on a
large site previously occupied by the PMC Marine boatyard. To minimally
meet a City of Seattle zoning requirement that lakeside development
must be restricted to "marine related uses", the condo developers
have included a couple of docks in their project, (almost certain to be
reserved for the exclusive use of the folks buying 7-figure lakeside
condos). Among the directors and major contributors to the Puget
Soundkeepers Alliance is at least one individual with extensive real
estate holdings along the shores of Lake Union and the Ship Canal.
Given that selling out to a condo developer would seem far more
profitable than leasing land to a boatyard, one has to exert a
deliberate effort to avoid suspecting that something other than
unbridled environmentalism and philanthropy could possibly be inspiring
certain supporters of the Puget Soundkeepers Alliance.

Not only is the total lack of a control number a glaring example of
disingenuous pseudo science, the refusal of environmentalists to
adequately consider the dilution factor of the body of water into which
storm water runoff is discharged seems additionally arbitrary.
There may indeed be valid studies indicating that salmon are adversely
impacted at levels above 3-4 ppb, but very few salmon will be swimming
up a storm water discharge pipe to spawn. It is doubtful than a salmon
would survive for any length of time in the discharge pipe from the
West Point or other municipal sewage plant, but accurate evaluation of
sewage discharge also considers the diluted results of the discharge
miles away from the mouth of the pipe, rather than measuring the
concentrated effluent itself. According to the College of Ocean and
Fishery Sciences at the University of Washington, there are 43.6
trillion gallons of seawater in Puget Sound. That's a lot of water
for salmon and other marine life, so no species will ever be required
to live in a drainpipe.

We urge the Pollution Control Hearings board to uphold the NPDES permit
issued by the DOE. An 80% reduction of copper runoff from boatyards
from a typical 2000 ppb level to 384 would be a significant step in the
right direction, and we have no way of knowing whether storm water
runoff from any source could be as pure and pristine as the 3-4 ppb
demanded by the environmentalists. When the permits next come up for
renewal, additional information about comparable copper runoff may be
available and it could indeed then be timely to seek a reduction from
the new 384 ppb standard. We additionally urge the boatyard industry to
research, develop, and apply bottom coatings that are as
environmentally benign as possible while still adequately effective.