- Knives kill people
- We know people die
- We know that nearly everyone owns one or more knives
- Therefore, all people die from knife wounds
This is not very different from the logic employed by Shireene Hale regarding stormwater toxics and land use controls. Come to think of it, it's not much different from the views of some people at Ecology either, and they should know better. Let's use copper as an example
- In certain concentrations, copper can affect salmon's sense of smell
- We know certain salmon populations in certain streams are in trouble
- We know copper can be found in runoff
- Runoff in the San Juans is killing salmon and we need new severe land use restrictions to deal with the problem
Make sense? Didn't think so. The dots don't quite connect.
In the email below, we see Hale distribute a toxics report from Ecology that she believes justifies and supports her position on the CAOs. She thinks it connects dots. It doesn't. Even if the dots did connect, the report wouldn't support the need for greater land use controls so much as greater pollutant source controls.
Hale has often dismissed the idea of pollutant source control as being impractical, and she continually wants to "solve" environmental problems with land use controls only. However, the whole point of the Ecology toxics report was to justify state programs for controlling pollutant sources through product reformulation. It was used for exactly the activity Hale dismisses, which also would obviate the need for land use controls as a solution for the same "problem" at the local level (assuming there was such a problem here in the first place).
Using land use controls to solve environmental problems without any regard to source control (or source identification) is bad policy and bad science. It would be like giving a person an antidote without checking to see what poisoned them in the first place, or without investigating whether the poisoning was ongoing.
Even if Hale and the County don't want to engage in source control, the State does it anyway. Every year, the State passes new laws, and the regulatory agencies write and revise their regulations, including new rules about toxics. Our runoff will become "cleaner" regardless of what our County does. Despite that, it doesn't stop Hale from wanting to be stricter at the local level too.
San Juan County ... so many solutions, so few problems.
The original email contained an attachment which can be downloaded here. Surprise, surprise, it was produced by Herrera, one of the consulting regulars who also is a consultant to San Juan County.From: Shireene Hale <email@example.com>Date: November 30, 2011 9:33:18 AM PSTTo: Rachel Dietzman <firstname.lastname@example.org>, Scott Rozenbaum <email@example.com>, ESTO461@ECY.WA.GOV, "Anderson, Paul (ECY NWRO SEA)" <paan461@ECY.WA.GOV>, firstname.lastname@example.org, Steve Belluomini <email@example.com>, Janet Alderton <firstname.lastname@example.org>Cc: email@example.com, firstname.lastname@example.orgSubject: General Stormwater Toxics Report