Friday, August 24, 2007

Lake Whatcom Storm Water Management: Entranco Report Redux

Yesterday's blog received feedback that Whatcom County is looking at ideas of how to set up a Stormwater plan to include all of Lake Whatcom, which is good news! Along with the feedback was this URL link to a recent feasibility study report to create a regional stormwater utility in the Tahoe Basin:

It will be interesting to see what happens, how soon, and how the County decides to pay for it.

With that introduction, here's a little history on the subject of Stormwater and Lake Whatcom:
On May 1 2002, I answered a Herald 'Hot-Seat' question from Gary Reid, then President of the BIA, with the following:

"That development is a primary cause of water quality degradation is generally true for any watershed, not just Lake Whatcom. This conclusion is rooted in widely accepted knowledge, based upon the extensive research of qualified experts. Our Lake Whatcom is special not only because it is the public water supply reservoir for over 85,000 people, but because it is a rarity in nature – a large lake of exceptional purity.

What a blessing it is for any community to have such a pure source of water! Many other cities, like Seattle, Tacoma, Everett and Portland, have chosen long ago to protect their essential water supplies against the risks of contamination and future unnecessary clean-up costs, by severely restricting uses in their reservoir watersheds.

The City of Bellingham and Whatcom County are only now becoming fully engaged in facing the serious problem of ensuring the sustainability of the Lake Whatcom Reservoir for future generations. It is the duty of these governments to tackle this task and to develop a sensible, effective approach that fairly takes into account the concerns of all potentially affected interests, most importantly citizens.

The so-called “Entranco Report” is one of the tasks identified in Phase I of the Lake Whatcom Comprehensive Stormwater Plan, and currently remains a work in progress, although an early draft was circulated for comment on November 22, 1999. Both City and County are working to improve stormwater runoff issues in this watershed, without waiting for this particular report to be finished before taking action."

ENTRANCO, a Bellevue based consultant with good credentials for stormwater work - but with minimal experience in working with public water supplies, like Lake Whatcom - was the firm selected for this work. So, predictably, the initial draft issued lacked adequate consideration of that essential point, and even seemed biased toward denial that the primary use of Lake Whatcom was as our source of drinking water!

The entire report is lengthy, now outdated, and was redone -after a 3-year delay- after peer review. Since that time, little has changed regarding actual progress on a County Comprehensive Stormwater Plan for Lake Whatcom.

Anyway, in late 1999, I did take strong exception to ENTRANCO's draft report, and my initial comments, submitted on 12/4/1999, are listed below. Later, I reviewed this report in much greater depth to see what might have been the motivation for the short-cuts that were being touted, and that was most revealing! Those comments are also posted below.

My apologies -again- for the reference to a lengthy document that is not immediately accessible. Despite that, these comments do reflect some very specific concerns that may not require reading of the Draft Report to understand.
Initial Comments:

1. No new "solutions", data or conclusions have been offered. This seems merely a $35,000 summarization of existing reports for someone's convenience of review. Is this what was intended?
Additionally, summary comments like these two, found on page iii of the Introduction, seem particulary inane, misleading and out of place in view of the non-comprehensive scope of this work:

"Based on our work, there have not been any notable trends in water quality over the last ten years."

"Although scientists have agreed to disagree on the dissolved oxygen trends in Basin 1 of Lake Whatcom, we do not think it would be productive for the scientific community or the public to continue the dissolved oxygen debate."

Frankly, I'm disappointed that no real expertise or advice over what has already been heard is being offered by the consultants. This may be due to a combination of factors, including

(1) initial limitation of scope and budget (who wrote it? & who decided the budget?),

(2) a measure of timidity in the face of a politically charged atmosphere surrounding the Reservoir,

(3) a failure to identify persons with the right training & experience (relating to drinking water source protection) to
(a) analyze the problem in depth,
(b) write the scope/approach required,
(c) estimate the costs,
(d) get all the necessary funding,
(e) select & supervise the consultants and
(f) interpret the results correctly.

2. The Bellingham community wants and deserves a much more comprehensive study approach, oriented toward preserving our resource, not just continuing to test the water and eventually having to recommend expensive actions to fix problems that we know are occurring now and will continue to occur at an accelerated pace with more development.

This study limits itself to a business as usual approach in primarily addressing only structural remedies, which are always more costly and less reliable than non-stuctural methods. It seems the essential cost/benefit analysis of alternatives will have to be done without the possibility of comparing the least expensive and more effective choices! This approach makes no sense at all and deserves to be called stupid and shortsighted.

Why is the Lake Whatcom Management Team continuing to take this easy, short-term approach despite the growing concern of the 66,000 citizens dependent on the lake for their drinking water, who are demanding a more effective program to be conceived, funded and carried out?

3. Like the recently issued DOE report, which used the words "Drinking Water" in its title, this report makes the same mistake of comparing Lake Whatcom's watershed to other "Urban Watersheds" and not other Drinking Water Reservoirs!
Why does this mindset persist, despite repeated requests for this specific comparison? DOE water standards have little to do with drinking water standards, except as a first line of defense in the potable water supply.
Drinking water standards are administered by the Dept of Health, and their importance is never mentioned in this report.

A big part of the problem might be that between the DOE & DOH standards lies a big, expensive "gray area" called a water treatment plant, which the City had to build in 1968 and subsequently upgraded at a cost exceeding $50 million, paid for by taxpayers and water drinkers.
Many who live in the watershed or own property there, do not participate in this expense, and therefore may not see it as their problem, preferring to "externalize" it to the City. Accountability for the water quality entering this plant is therefore lacking.
Without appreciating the necessity for the water to be anything other than "treatable", we have created a problem that will continue to escalate. Indeed, we could design a plant to produce drinking water from sewage, but costs would be astronomical (as in NASA). The Navy & Saudi Arabia both produce their drinking water from seawater, also quite expensive. Other exotic treatment methods also exist, all proven but expensive.
But, with a wonderful natural freshwater source like Lake Whatcom, who in their right mind would willfully (or even unwittingly after knowing the "lake" is actually a "reservoir") pollute it, risking health & ecology in the process and ultimately condemning the citizens to paying for expensive, and largely avoidable, treatment?

DOE is not enforcing its mandate of keeping the lake "fishable & swimmable", which in itself would go a long way toward meeting drinking water reservoir standards. At the high fecal coliform levels now in the lake, children and immune-deficient people are already in particular danger. Also, according to DFW, the two native trout species are near extinction due to lack of the habitat necessary for species to reproduce naturally. Run-off from dumps, development, recreation activities & impervious surfaces is adding nutrients, metals & other toxics to the lake every day, further accelerating degradation of the waterbody. And yet, this report is able to conclude:

"Based on our work, there have not been any notable trends in water quality over the last ten years."!

I wonder just what "work" this is based on, other than a review and regurgitation of previous, inadequate reports?
Its very difficult to see any real value to the community added by this exercise, especially since it blatantly ignores
(a) the fecal coliform 303(d) listings,
(b) recent mercury findings in fish tissues,
(c) imminent listing of fish species specific to Lake Whatcom,
(d) the revelation that between 600 and 7500 new homes are apparently expected to be built in the watershed during the next several years,
(e) near passage of Proposition 1, which would have raised $4 million/year for 20 years to purchase land in the watershed as natural buffer, eliminating development,
(f) Dr. Robin Matthews' recent study showing an unusual jump in oxygen depletion levels in Basins 1 & 2,
(g) the real possibility of losing or lessening the Middle Nooksack Diversion flow for ESA purposes,
just to name a few "notable" events happening recently.
Is it possible these are indicative of a "trend"?

Is it possible that Lake Whatcom is not getting the attention it deserves because Bellingham is not yet a city of over 100,000 and does not have sufficient jurisdictional control over protection of this resource? That seems to be EPA's guideline.
But, to complicate things further, EPA then delegates its Clean Water Act responsibilities to DOE and its Clean Drinking Water Act responsibilities to DOH. Where do these different responsibilities recombine?
What is the County Health Department's role?

Perhaps our Lake Whatcom Reservoir is such a unique watershed, already complicated by "multiple uses", that our Federal/State agencies are confused over who does what & what to do? As tempting as it is to blame these remote government agencies, the real responsibility for demanding proper attention is with us, the local community, both citizenry and County & City governments, to first recognize the true nature of the Lake Whatcom Reservoir problem and then to comprehensively initiate the necessary studies and require the necessary actions be taken, preferably before really bad things do happen. This takes political will, leadership and informed action, despite vested interests who might prefer not to hear about potential problems or participate in their solution for the benefit of future public health.

The Olympic Pipe Line Disaster should have already demonstrated to us what can happen if ignorance, complacency and lack of adequate regulations & enforcement persist too long! It also demonstrates what power the local community has to effect change, when it is clearly needed.

4. Future study work should undoubtedly include modelling, which can be an effective tool for predicting future water quality effects resulting from increasing use of the watershed for human activity. But this modelling itself must be based upon enough data to comprehensively characterize the watershed! For such a model to be fully effective, proper non-structural elements, such as zoning & land use parameters, buffers for critical areas, stormwater performance standards and the like, need to be put firmly in place.
Where will this additional data come from?
Who will define it, develop it, pay for it, use it?
How long will it take to put an effective watershed plan into practice?

These are the questions our community is expecting to have answered. Please tell us what it will take to get these questions answered! If the expertise to obtain comprehensive answers to these important technical questions is not available locally or in Seattle, then let's search for professional help elswhere.

The Lake Whatcom Management Team needs to recognize this as a top public health priority and give it the attention and funding it deserves! In the mean time, time is passing....

Entranco Report - Additional Comments

I have now studied this report and watched the video of the 11/17/99 public meeting. Here are additional comments to complete my initial feedback to this report. Although the report does pull together diverse information of interest, particularly on applicable regulations, its overall added value to the LWM Program remains problematic and marginal in my view. The results of the Peer Review Committee [PRC} review process will be of major interest.

1. My expectation (and apparently that of others, per Chris Spens' comments at the meeting) was that ALL prior data, covering decades, would be reviewed, not just the last 10 years as stated by Dale Anderson. Who decided only one decade would be considered instead of several?

2. I believe it is necessary to scrupulously separate fact from opinion, and carefully define what is meant by "notable" trends. Something that might not show a definite trend over 10 years, might well show a "notable" trend over several decades (like HODR calculations-see below).

3. Regarding the statement regarding "disagreeing scientists" and whether "debate" over HODR levels/trends is important. I believe this is critically important for the same reasons cited on page 23 of the report:

a) It is the basis for DOE's 303(d) listing of the lake, demonstrating a clear trend toward accelerating eutrophication, an early indication of water degradation in Basin 1, violating of DOE's "Antidegradation Policy".

b) If degradation is established, then:
• "beneficial use" may be considered impaired;

(note Entranco interprets this as NOT directly prohibiting pollution discharges and NOT meaning observed changes in concentrations of particular parameters indicative of water quality, but that 'impairment' must actually be proven to occur! Should the burden of proof of actual impairment be on water drinkers, swimmers and fish? I don't think so! This is why a comprehensive EIS approach is needed to wisely guide future activities in this uniquely valuable watershed. If DOE has reason to conclude that impairment is happening (as indicated by the HODR trend) then we need to listen to them! This type of trend would not likely be apparent to anyone but experts who have long term experience in testing Lake Whatcom, and we should be glad to have an early warning of accelerating eutrophication in Basin 1, whether this can be proven as indicative of the entire lake's condition or not! )

• evaluation and implementation of all reasonable options are required to prevent deterioration of water quality;

• activities causing pollution in the watershed can be regulated and prohibited if not found to be in the public interest.

This appears to be a very high stakes game! Perhaps we should change the game and raise the ante by getting another impartial opinion from an acknowledged expert from outside the Northwest with this expertise, if one can be found.

4. It is readily apparent that much effort has been devoted to discrediting or discounting the DOE 303(d) listing based on HODR trends in Basin 1, to the point that I am reminded of the Shakespearean phrase "methinks she doth protest too much". I plotted the data shown in Appendix B myself. Here are my findings:

a) Based on conventional arithmetic graphing, followed by averaging of DOE & Envirovision calculation results and visually plotting a trend line, a definite UP trend is indicated, approximating 5.8 HODR units per year.

b) I plotted both sets of data on semi-log graph paper. Slight trends could be noted visually in both cases, using data taken over the last 10 years, however, because of the small scale used and data scatter, accurate visual trend determination was difficult.
I re-plotted the data, using data reciprocals (1/x) and was able to see more clearly slight trends in each of the data sets, which appeared to agree fairly closely with each other. This encouraged further examination.

c) I then tried a computerized graphical technique in use for years for evaluating and forecasting stock trend data like sales and earnings per share over time. This technique uses 10-year historical data to forecast future values based on extrapolation of least-squares trend lines on semi-log paper. (abscissa = year; ordinate = values)

Both DOE data and Envirovision data were plotted side by side for comparison. The resulting plots further confirmed the prior visual observations, and also assigned per cent "growth" values to each of the trend lines based on their respective slopes.
The DOE data showed +2% per year historic "growth" over the years 1988-1997. Using the "Rule of 72", it would take 72/2 = 36 years for the 1997 HODR calculation to double in value (415 to 830), assuming this "growth" trend continues that long.
The Envirovision data showed +2.5% per year historic "growth" over the same period. At this continued rate of "growth", about 28.8 years would be required to double the 1997 HODR value (347 to 694). Compounding 2.5% "growth" for another 7 years (total of 35.8) on 694, results in a total of 825, very close to the 36-year total projected for the DOE data.

This indicates that both sets of data agree closely in their respective 36-year projections. I would welcome verification of both the technique used, results obtained and their interpretation by those more knowledgeable in these areas.

5. The HODR question won't just go away despite any debate. Does HODR show a measurable change from natural conditions or not? (per page 24) If meaningful trends can be determined by this method, or another, as an early warning, so much the better. We know that even pristine lakes undergo natural degradation, but this process may require a thousand years or more. We also know that this process is accelerated greatly by development. The point is, let's find out as soon as possible, the rate of degradation happening in Lake Whatcom, basin by basin, so that we have a better chance of arresting this slow degradation and sustaining beneficial uses. Future loss of the Nooksack Diversion would only exacerbate the situation by reducing turnover substantially.

Additionally, Lake Whatcom may be a truly unique, "atypical" water body, given its rare combination of hydrology and beneficial uses which include drinking water supply. What other lakes have been identified that truly compare in all these aspects? Who has actual experience in protecting these? What methods are most effective, both in terms of water quality and costs? How could a program be instituted here to insure a safe and sustainable water source for our chidren and beyond?

6. Assignment of specific "Issues & Problems" to each of the three "Beneficial Uses" (pages v, vi, vii/viii) needs additional explanation. In reality, I suspect these may be interrelated in varying degrees. For example, Eutrophication and HODR issues are assigned to the beneficial use of Recreation. Is this specifically correct or somewhat arbitrary to simplify presentation of data? In a multi-use lake, where all uses are considered important and interrelated, substantial overlap of "Issues & Problems" seems likely. In this respect I can visualize using three circles, labelled A (Drinking Water Supply), B (Recreation) and C (Fisheries & Other Aquatic Life). Each circle, containing its own quality criteria, overlaps the other two to some extent. Where all three circles commonly overlap should define the area of main interest and criticality, like a syllogism in logic. If such a holistic approach makes better sense, then let's use it to guide our future efforts.

7. Now that reasonable funding has been made available for two years and assignments like this water quality assessment are finally getting done, efficiency seems important and it is, providing we're doing the important things correctly and in proper sequence.
However, accountability is even more important since this is necessary in assuring the very credibility of the work done to the public. To date, I feel there has been a lack of accountability to either the public or those of us in elected office in disclosing the overall efficacy of the program we are pursuing.
While the tasks and objectives shown in the annual work plan generally follow the goals of the Joint Resolution, it is not clear that a long term course of action is in place that clearly prioritizes prevention/protection over structural remedies and institutionalizes the path toward preserving our most valuable water resource.
If the program visualized is believed to be truly comprehensive and likely to be effective, why the continued reluctance to open the decision-making sessions to the public? Many in the community who would like to be more a part of this are being systematically excluded from the process and find this increasingly troubling. In a situation this important, sensitive and politically charged, it would seem prudent to let this process be done in daylight. That also happens to be State Law.

8. Water Supply System (pages 5-21)
Thanks for including this section. It's nice to see this summarized in one place.

A few questions & comments:

• It would be particularly valuable to see what changes in conditions occurred before 1968, when building the City's water treatment plant was justified at major public expense.

• Same comment regarding Water District #10 water treatment plant.

• The JMM 1986 Study made comparisons of Lake Whatcom raw water with several other UNTREATED water supplies on the West Coast. This is a meaningful comparison basis and should be done in every case.

• It is troubling to read on page 8, 1st paragraph, that "Impacts are not based on the changes of concentrations of contaminants within Lake Whatcom (source water), but rather on whether a particular beneficial use is impaired." and, "It is understood that the goal of the water purveyors and their customers is to prevent any degradation of the drinking water or to have water that imparts no or minimum risk." This means that its the PURVEYOR's problem if raw water is degraded! Is that correct? Where's the teeth in PREVENTION!
Even worse, "...water quality for the purveyors is compared to existing regulations, rather than anticipated future regulations." This seems to mean purveyors can't do anything but react to changing conditions, after they have occurred, and at their cost! Incredible!

• The discussion of MCL's and their enforceability is both interesting and frustrating.
For example, on page 9 last paragraph, reads: "We apply the MCL to samples collected in Lake Whatcom, for comparison purposes only, because the level of a contaminant in the source water does not relate to the concentration in the treated water." This seems to confirm that any escalation in source water contaminant level must be duly noted by the purveyor, who then must adjust its treatment technology accordingly. Again, where's the teeth in prevention of pollution? It seems the DOH is only there to monitor and advise the purveyor when its in trouble.

• Page 12 notes that the WWU monitoring program focusses on parameters that are not regulated by primary or secondary drinking water standards, and that none which have associated MCL's showed exceedences. Is this why the HODR "debate" is not considered important?

• The section on Pathogens is not comforting. What it says is that we are at risk for anything chlorination can't kill. No more sewage overflows!

• Regarding who pays for degradation effects, the principle should be "he who pollutes, pays". No subsidies by taxpayers or ratepayers for polluters! LID-type permit & latecomers fees.

• Example from California per 12/9/99 San Francisco Chronicle article:
New Los Vaqueros Reservoir, north of Livermore- (restricted use/no development)
20,000 acres vs 31,500 acres in Lake Whatcom watershed (63.5%)
100,000 acre-feet vs 774,000 acre-feet in Lake Whatcom (13.5%)
400,000 ratepayers vs 65,000 in Lake Whatcom (615%)
320 gpd average daily use vs 236 gpd in Lake Whatcom area (136%)
$42/month average water bill vs $18.50 in Lake Whatcom area (227%)
$10-$12/month = portion of water bill attributed to reservoir cost (23.8% to 28.6%)
$450 million = cost of 1988 bond issue (12 years to construct dam + pipeline & pumps from Central Valley + environmental mitigation + management of 20,000 acre watershed (ongoing)

9. Recreation (pages 21-41)

• It is interesting that this particular beneficial use was given this much space, and that this is where coverage of DOE's antidegradation policy, State Water Quality Standards & HODR is given. Is this because recreation uses cannot depend on a treatment plant for purification?

• The arguments given on page 29-41 seem to do more than report standards; they appear to be arguments to strongly support a position. Is this true? Why?

• Why is it preferable to base calculations on "...mean epilimnetic values ...rather than the ranges or individual samples of extreme concentrations or samples collected throughout the water column."? Is this for convenience or custom in characterizing a large water body? Is it meaningful to average values, even though the lake's known morphometry clearly shows distinct divisions, like Geneva & Strawberry Sills separating the basins?

• Comparisons now seem to shift to other lakes that are not water supply reservoirs. Is this true? Why? Are we mixing and matching data fairly?

• The conclusion at the bottom of page 33 states: "...there is no indication of a trend in trophic parameters." Does this include HODR trends or only Chlorophyll a, Total Phosphorus & Secchi Depths? See paragraph 4, above.

• Figures 10, 11 & 12 show "Temporal Trends in Trophic Parameters". Can we also focus on data records by month over time to check for seasonal temporal trends in a chronological format?

• Page 35, last paragraph: has Entranco checked for HODR trends in Basin #1? (see P4. above)
Figure 16 on page 36 is a straight arithmetic graph, using data from 11 of last 15 years.
Why is it so important to prove Robin Matthews views toward HODR & its trends wrong?

• page 37: Explain why increasing detention time (hydraulic residence time) would not be a problem. The statement regarding fecal coliform destruction due to exposure to sunlight may be correct. However, it seems dilution in mid lake would largely mask this contamination.

• page 38: 2nd paragraph, re estimates of detention time, this reasoning needs to carefully explained in context, much better than the over simplified version stated quickly. Updates of morphometry will HELP explain water distribution and movement, but I fail to see how this will resolve anything, in and of itself.

• Regarding fecal coliform sampling: it seems too few samples are being taken at too infrequent intervals to provide reliable background data. Plus, when testing is being done, samples are being taken at the wrong places! What good does an average result do when it represents occasional mid-lake conditions? While water skiers and some others are in the water at mid-lake, a far greater number of people (and most children) usually swim at beaches or nearer shore. Are continuous (or semi-continuous) sampling devices or techniques available for use at public outfalls like Park Place Drain and Silver Creek and the public beach at Bloedel-Donovan Park? In examining King County's program in north Lake Washington, one has to be on one's toes to capture fecal coliform data during periodic "spikes". What is anticipated from discussions with the Bellingham School District? Funding? How frequently does the County Health Dept. look at this problem or post warnings? Would more citizen complaints help?

10. Fisheries (pages 41-46)

• Inclusion of data and associated interpretations from recent DOE Report seemed perfunctory and not completely integrated into this report. Statements like the last paragraph of page 45 seem to have been made without much thought, almost discounting the potential importance of this new data. The summary of toxic-related water quality problems based on the DOE report were exceedingly terse, failing to point out that this was the first time excessive levels of mercury were ever found in Lake Whatcom fish! One composite fish tissue sample IS important, precisely because it is an average of a toxic, bio-accumulative substance ingested by aquatic life that represents life in many parts of Lake Whatcom over years!

• 2nd bullet at bottom of page 41 estimates 2000 to 10,000 moralities (mortalities?)

• Loss of natural fish habitat due to practices causing silting, loss of cover, blockage and addition of toxics is a no-brainer. WDFW has been telling us that for years. HODR could also be an indicator of fish mortality or change in habitat. After all, bubbling air through aquariums is standard practice for those who want their fish to live for a while.

• Protection of fish species, in general, would be an ideal practice to prevent degradation of water quality. (Witness current ESA for salmon, etc) G-P and other industrial plants with effluent discharges routinely use "fish tests" to check for residual toxicity before releasing waste water into the environment. (canary in the mine)

• In some respects it seems the presence and use of fish hatcheries to reproduce fish serves the same purpose as a water treatment plant. That is, to give society a short-term reason not to abide by good rules to protect natural sustainability of resources.

11. Causes of Water Quality Problems (pages 47-55)
This short section adds little to what is already been said and, predictably, relies on future studies. There is no question that future study is needed, but I am more convinced than ever that a much more comprehensive program is needed in the interest of future generations.