(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.

On 18 Jun 2006 02:06:39 -0700, "
wrote:


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.

From this paragraph, it sounds like your 'environmentalists' are trying to
sneak into the eminent domain business. I wonder how much those folks on
the board are *really* making.
--
John H

******************************************
***** Have a Spectacular Day! *****
******************************************

wrote:
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.


The way to approach this would be either area samples,
showing (or failing to show) a gradient in copper ppb, or
perhaps it would be more efficient to take point samples of
other runoff discharges.

It's true that boatyards are an environmmentally "dirty"
business and should be required to take steps for pollution
abatement. But it is neither right nor effective to put
boatyards out of business, or simply run up the costs, when
everybody else is getting a free ride. Of course, this also
suggests a way for boatyards to cheat... pipe their drainage
to somebody else's runoff.

Maybe a countersuit requiring the Riverkeepers to show
copper levels all over the affected area waters?

Regards
Doug King

There may be a way to slow down or prevent similar problems in the future.
If this Puget Sound Keepers is a government funded (a Mag-Stevens mandated
group or other), the group leadership has to be made up of representatives
from specific areas. IE, a sportfishing rep, a commercial fishing rep,
marine biologists, city reps, etc.
One such grouping is Marine Resource Committees. These groups are set up
around Puget Sound to protect marine resources. They do have openings from
time to time. Strictly voluntary but it does give you a chance to vote on or
argue for good sense resolutions.
For instance, The San Juan County group would like to make a marine
sanctuary out of all the San Juan islands. This might feel good to some but
where is the science behind it? What do they figure to save? How many? yada
yada.
The best thing is common sense management to prevent overharvest while at
the same time making good use of the harvestable numbers.

I guess what I'm saying is, if you don't like the way things are, get on
the committee so you can have a say!

Get involved!

I represent sportfishers on the Clallam County MRC which means the western
end of the Straits of Juan de Fuca. We have a very diverse group working on
a number of things.

BTW We have a joint meeting/barbecue tomorrow night with the Jefferson
County MRC. I know they have some rules about individuals making comments to
the press but if you just happen to wander by and make some observations or
ask some general questions.......

See you tomorrow?
Gordon


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




Disingenuous Pseudo Science