Friday, March 23, 2012

The Problem - Fallacy, Bureaucratic Dreams, Compulsion

A few days ago, Sharon Kivisto wrote a brief article revealing "the problem" with our local environment. She's not the first one to do so. Back in February 2011, San Olson of the Friends wrote a letter to the Island Guardian where he concluded that the problem was "all around us." (Also, see previous post about Friends and (In)Credible Data).

Sharon's thesis relies in large part on the local 303d water quality reports done by the Department of Ecology. That, in itself, is not a problem, and in fact, I often advocate using the 303d and 305b reports (which are requirements of the Clean Water Act) as one line of evidence regarding our environmental quality.  It is true that the 303d reports identify some of our waters as impaired:  there are 11 instances, out of 378 database entries, showing that some of our waterways are "impaired." Of the 11 impairments, 7 are because of fecal coliform; we also have two of our marine waters listed for low dissolved oxygen levels; and lastly, we have two waterways listed for two different reasons: Mountain Lake in Moran State Park for PCBs and Horseshoe Lake on Blakely for phosporous.  Yes, you read that right. Mountain Lake in Moran State Park is identified as one of our nation's most impaired waterways because of PCBs. More on that in a moment. Let's examine these results by group.

Let's start with fecal coliform, which is one of the most widespread forms of pollution in the US. Contributing sources for fecal coliform pollution include humans, pets, livestock, and wildlife. Without knowing the relative contributions of each source, it is impossible to determine an appropriate remedy. For all we know, the source of the high fecal coliform levels may be wildlife sources. One way we could distinguish the sources from one another would be to perform genetic tests on the coliform bacteria. Even so, the 303d coliform data itself is somewhat suspect. The 303d listing was based primarily on data that is 10 years old or more, and the more recent data (2003) is accompanied by the admonition that these data "may not meet minimum data requirements of Ecology WQP 1-11." In other words, the data quality for coliform is questionable, and what doesn't explicitly fail state data quality standards, is old.

Moving on to dissolved oxygen (DO), low DO was measured in East Sound and San Juan Channel. It may have an anthropogenic cause, but then again, Ecology's notes for the 303d report do not clearly point the finger to humans. In 2004, the evaluation for East Sound even said:

These excursions beyond the criterion are a natural condition with no direct human-caused influence due to natural variations in the marine environment, based on the 11/03 judgment of Jan Newton (Dept. of Ecology).

However, by 2008, a different Ecology employee opined that human factors may be influencing the results and further analysis was warranted. Yes, further analysis is warranted, in my opinion, especially because the 303d DO screening level used for the San Juans is 40% higher (i.e., more strict) than the DO criterion used for saltwaters elsewhere, making "failure" here more likely.  In the San Juans, the criteria used was 7 mg/L of DO, which is 2 mg/L higher than the saltwater aquatic life criterion set by EPA in other places (e.g., Cape Cod to Cape Hatteras, 2000). And the sample sizes used in the DO analyses were very small. We don't know enough about the statistics of these small data sets (e.g., the mean, standard deviation) to properly evaluate the confidence limits of the data relative to any screening criterion. In short, it is impossible to say whether there is a DO problem, statistically speaking, and the data interpreters at Ecology do not seem to be able to point to a clear cause for any problem.

Now, let's look at the reports of contamination at Mountain and Horseshoe Lakes. Both of these lakes are situated in protected areas without any nearby development. The 303d note for Horseshoe Lake cites a study by Ecology (Welch, et al, 1992) from their "Lake Restoration Program." If you look up that report, you will notice that the Horseshoe Lake in that report is in Clark County. Based on that, it appears as if the 303d report for Horseshoe Lake in Clark County erroneously found its way into our 303d report for Horseshoe Lake on Blakley Island in San Juan County. It's very likely that there never has been a water quality issue at our Horseshoe Lake, and the 303d listing for us is just a case of bureaucratic confusion and mistaken identity.

As for the PCBs in Mountain Lake, the notes in the 303d report indicate that the sample was taken from the tissue of a kokanee salmon in 2004. PCBs are deposited atmospherically, like many pollutants, so it is possible that air-deposited PCBs are accumulating in the tissues of Mountain Lake kokanee. However, hatchery raised kokanee are stocked into both Cascade Lake and Mountain Lake, and hatchery fish have been known to carry PCBs into the ecosystem from the hatchery. I would not be surprised if the tested Mountain Lake kokanee was a hatchery-raised fish that had picked up PCB contamination at the hatchery, similar to what happened at Icicle Creek in Chelan County.

As for other arguments made by Sharon, she points out that the number of species of concern for the Salish Sea increased by 23 over the past two years. However, the term "Salish Sea" was only approved by the U.S. Geographic Board of Names in late 2009 and Canada didn't approve it until 2010.  It is, therefore, not surprising if data are still being compiled and correlated to this new geographic designation. The additional species listings may reflect circumstances related to the change in geographic nomenclature and categorization rather than species decline. The Salish Sea encompasses a huge area, from Desolation Sound to Oakland Bay, so re-categorization is likely to take a while to sort out.  Also, given a population of about 6 million people in this vast region, our 16,000-strong County represents 0.3% of the potential human contribution to Salish Sea anthropogenic issues.

Sharon's article also contains several fallacious arguments. For example, she quotes Gaydos as saying, "nearly 60% of the bird species and 30% of the mammals that need the Salish Sea also require terrestrial resources to survive, illustrating the intimate link between the land and sea and the need to conserve both." In saying this, Sharon is implying a post hoc fallacy in reverse: that avoiding further conservation measures here will prevent Salish Sea species from obtaining the terrestrial resources they need to survive. That's a flawed argument based on false premises, and it's like saying that if we prevent the rooster from crowing, we will stop the sun from rising.

In sum, the discussion of "here is the problem", whether it has been advanced by Sharon Kivisto, the Friends, consultants, or various government representatives, has been mostly kettle logic: using multiple inconsistent arguments to defend a position.

The problem isn't the environment. It is flawed logic and the deceptive exploitation of environmental claims to advance bureaucratic dreams, self interest, and compulsion. It's the unjustifiable smugness of people who feel they know more than you do, giving them the right to tell you how to live.


  1. We have asked for years for some documentation of the "pollutants" that are apparently all around us, and--if there are such pollutants--what percentage of them come from homes, what percentage from agriculture, what percentage from wildlife (yes, wildlife, including deer and other critters, routinely foul streams and ponds), and what percentage from commercial development. No answers. After the March 6th Planning Commission, at which the most oft-repeated phrase from our planners and scientist was "we know nothing," some commissioners asked Dr. Adamus for a list of the pollutants of concern. He has, as yet, not supplied this. But we are about to apply the same "prescription" to all those uses, assuming that they all produce these elusive pollutants. This just seems crazy to me. As well as unconstitutional, given the nexus and proportionality requirements.

  2. It also seems odd that no one in Planning seems concerned that we are supposedly living with all these "pollutants," day in and day out. What effect do they have on people? I realize that most of our living creatures are smaller than people and subject to harm at much smaller doses, but shouldn't we be given information about these pollutants so as to consider protecting ourselves/

  3. ECK says, "That's a flawed argument based on false premises, and it's like saying that if we prevent the rooster from crowing, we will stop the sun from rising," as a result of this, "...avoiding further conservation measures here will prevent Salish Sea species from obtaining the terrestrial resources they need to survive."

    This is incorrect. First, your point is not based on what Ms. Kivisto said, but on what Mr. Gaydos is saying. Thus you are actually at fault for connecting thought A with thought B when no connection is viable. Second, the point isn't directly correlative to a Rooster crowing and the sun rising. It's much closer to the relationship between your house and a grocery store. Not directly dependent to each other, but both very important to survival. thus, you are creating a fallacy on both accounts resulting in misinforming your readers.

  4. I would like to comment on PCB's in Mountain Lake, is it odd to have the level found in a less than 2 year old fish to exceed EPA standards, how about Cascade Lake, fish there have sampled the same level of PCB's, then we have the study of Eastsound shellfish at Crescent Bay and at Buck creek were Cascade stream drains to the sea, The shellfish were noted to have high concentrations of PCB's. As a source the local power company is cited due to storage of transformers from back when, what I'm trying to imply is that there is a contamination site at higher elevation somewhere on or about Mt. Constitution, there is a rumoured dump up there and simply pass it off as a hatchery fish does no one any justice and to simply say the PCB's are present in the eastsound environment from the storage of transformers begs the question how does it get into these lakes that are over 800 feet in elevation, perhaps someone could do a study on Purdue lake.