When it comes to cleaning up bacterial pollution in Puget Sound, we seem to have a clash — or at least some redundancy — in the methods we use.
In Kitsap County, water-quality officials are saying studies conducted by the Washington Department of Ecology, which allocated total maximum daily loads (TMDLs), have not been much help in attacking the local pollution problem.
That’s because the approach developed by Kitsap County, called the Pollution Identification and Correction (PIC) Program, has been highly successful in tracking down and cleaning up bacterial pollution.
I wrote a story about this issue as it relates to Liberty Bay in yesterday’s Kitsap Sun.
I also talked a little about the two water-quality standards used for streams. It’s somewhat odd how Liberty Bay must conform to a stricter standard than nearby Dyes Inlet, since both are in urbanizing areas. By the way, there is only one standard for marine waters, and Liberty Bay is generally clean under that standard.
With regard to cleanup methods, now that PIC has been adopted and funded for the Puget Sound region, one might argue that it is time to back away from the more cumbersome TMDL approach, which spends a great deal of money to allocate pollution loads with no guarantees that any cleanup will get done. For recent funding details, review the Washington Department of Health’s Page on “EPA Grant: Pathogens, Prevention, Reduction and Control” and the specific funding for PIC projects.
Although I’ve heard the PIC approach being widely touted, I’m not sure state and federal water-quality officials are entirely sold on the approach, especially when funding is an issue, as it is in many counties. Kitsap County funds an extensive monitoring program through its Surface and Stormwater Management Fund. Each resident in unincorporated areas of the county pays an annual fee to support water-quality efforts.
One thing local water-quality officials have learned through the years is that pollution is a never-ending problem. Once a waterway is cleaned up, ongoing monitoring provides an early warning for new problems that show up.
A lot of bureaucracy has built up around the federal Clean Water Act and its approach to pollution problems, including the TMDL studies. The Environmental Protection Agency — and by extension Ecology — are under an out-of-court settlement to complete TMDL studies for all impaired water bodies.
Conditions of the settlement, which might complicate a shift away from the TMDL approach, are under renegotiation. It might be time for all the parties to focus a little more on the cleanup efforts and less on the studies themselves. I have no doubt that everyone wants cleaner water, but there is a lingering concern that changing the rules could have unintended consequences.
The Washington Department of Ecology has started to wade into this issue by placing some impaired streams on a 4b list, where they sidestep the TMDL process while undergoing cleanup. To meet the criteria, the local government must demonstrate an effective method of reducing pollution, a time schedule for completion and a long-term monitoring program, among other requirements.
A good explanation of this process is provided in a report by Helen Bresler with Ecology and Laurie Mann and Eric Monschein, both with EPA. See “Category 4b Demonstration for Pathogen Impaired Tributaries to Puget Sound in Kitsap County, Washington” (PDF 57 kb), which states:
“In Kitsap County, Ecology observed (that) progress towards achieving water quality standards was being made quickly, and decided that expending additional resources on TMDL development may slow down the work that was already underway. Once Ecology decided to support placing the Kitsap watersheds into Category 4b, Ecology worked closely with Kitsap Health District staff to develop the 4b rationale required by EPA…
“In Washington, Ecology does not use Category 4b as an up-front ‘tool’ to improve water quality. Rather, 4b listings document active efforts to get to clean water that Washington believes will be successful without a TMDL…. Because Washington sets a fairly high bar for putting waters into Category 4b, Washington is sometimes in a position of telling a group that Category 4b is not appropriate because one or more of the 4b requirements cannot be met with their efforts.”
For some reason, not all of the streams in Liberty Bay were placed on the 4b list, and we ended up with a $600,000 report that Kitsap officials say is not of much help in their cleanup effort.
Perhaps if more counties take note of this outcome, they will choose to develop complete, locally funded monitoring programs and attack the pollution at its source. The result could be fewer elaborate studies and more rapid cleanup. As I noted in yesterday’s story, several local counties already are taking the first steps in this direction.