To: David Greetham, Environmental Planner
Kitsap County Department of Community Development
As you know, the major pollutant of concern in local waters is fecal coliform — see Washington State’s Water Quality Assessment and 303(d) List. For Sinclair and Dyes Inlets, this is the only candidate pollutant even being evaluated by Sally Lawrence of Ecology for TMDL control. And far and away the largest anthropogenic (human) contributor of fecals in the local area are combined sewer overflow (CSO). Some studies suggest wildlife sources may actually exceed anthropogenic sources.
So, I found today’s Seattle Times article on CSO correction activities to be quite interesting — suggesting that further actions to reduce these CSO overflow discharges are not justified. It is noteworthy that Bremerton’s CSO control program, right here in the middle of Kitsap County, is the article’s poster child of what is wrong with the program to eliminate CSOs.
Indeed, the Puget Sound Partnership’s conclusion that pollution in stormwater poses the highest risk raises the question of whether the decision to eliminate properly functioning CSOs, which actually treat the stormwater’s “first flush” that contains the majority of stormwater pollution, was actually well thought out — as this first flush is now being largely released untreated to receiving waters in those jurisdictions where the sewage and stormwater flows have been separated.
All of which leads back to the question I have raised in SMP Update Task Force meetings — just exactly what nearshore pollution sources and pollution levels are we trying to attenuate with buffers on single family properties? And what is the justification?
For example, is exceedance of EPA’s water quality criteria and placement on the 303(d) lists the appropriate yardstick (it should be)? In other words, what is broken? What is the problem we are trying to solve? I would suggest we need to answer these questions before applying stringent buffer controls to private properties.
Board Member, Kitsap Alliance
P.S. You asked me if I was familiar with the four science references in Ecology’s new Chapter 11. The brief answer is yes — and that this gray literature has significant deficiencies — many of which Kitsap Alliance has already identified in peer reviews provided to the County and to Ecology.