Friday, April 6, 2012

The 9% Solution

Ever ride a bicycle in low gear? You pump your legs like mad, but make practically no headway. That's similar to the way buffers work, according to the Mayer paper, because there is a weak relationship between the inputs and outputs. Buffers can use up land like mad but make practically no headway on pollutant removal.

The Mayer paper calculates that only 9% of pollutant removal can be explained by buffer width.  John Wanamaker, an early pioneer in marketing, used to say that half the money he spent on advertising was wasted, he just didn't know which half. For a buffer-based world, we might say that 91% of buffer space is wasted, we just don't know which 91%.

Buffers can eat up lots of land for practically no pollutant removal effect, especially after they exceed a certain effective size.

Yesterday, our Planning Commission passed the draft wetlands ordinance of the proposed CAO. Giving credit where credit is due, they took a terrible proposal and made quite a few improvements. Overall, however, we still don't know what the problem is, if any, and the proposed CAO will force us to live in an inefficient, costly, buffer-based world.

Buffers are the 9% solution, and they're still looking for a problem.

Wednesday, April 4, 2012

How Many Ecology Employees Does It Take ...

Recent public records requests show the flurry of activity at Ecology when the Charles Dalton video surfaced. Ecology prepared a powerpoint presentation. They blogged about about the video. At one point, they had as many as 11 staff at all levels involved with developing a response. Eleven people! And what did Ecology's response say?  Well, in part, it said that Ecology had no authority in the matter at hand.

"We don’t have regulatory authority in local critical areas ordinance issues. We don’t make rulings or issue enforcement actions under local critical areas ordinances. Those tasks are on local government turf" (Gordon White, Eco-Connect Blog, Feburary 14, 2012.)

All that PR effort for a situation where they claim to have no authority?  The email below is just one example of the many emails related to this matter.  You can see there are eight people, including senior managers, involved in just one email.

The real question is why Ecology cares about their image in the first place. They're regulators, not movie stars. Yet, they have a blog, a Facebook page, and they seem to have a surfeit of "communications" staff.  Are they communications staff or publicists?

From: Anderson, Paul S. (ECY)
Sent: Friday, February 10, 2012 2:02 PM
To: Skipper, Katie (ECY)
Cc: Altose, Larry (ECY); Hart, Curt (ECY); Tallent, Geoff (ECY); Stockdale, Erik (ECY); Summerhays, Jeannie (ECY); White, Gordon (ECY)
Subject: RE: PLEASE REVIEW BLOG RESPONSE TO SJC YOUTUBE VIDEO

Katie:

Once again, thanks for your time with this.  I think it looks good.  I would suggest a couple of changes to the PowerPoint:

Slide 4, Bullet 1,  Wetland scientists educated and trained in wetland vegetation, soils and hydrology  [link to SWS-PWS Website?]
Slide 5, Bullet 1,  County asks for technical assistance

Paul

Paul S. Anderson, PWS Wetland Specialist Washington State Department of Ecology 3190 - 160th Ave. SE Bellevue, WA 98008 Phone: (425) 649-7148 Fax: (425) 649-7098 Email: paan461@ecy.wa.gov  

From: Skipper, Katie (ECY)
Sent: Friday, February 10, 2012 1:19 PM
To: Anderson, Paul S. (ECY); Tallent, Geoff (ECY); Stockdale, Erik (ECY); Summerhays, Jeannie (ECY); White, Gordon (ECY)
Cc: Altose, Larry (ECY); Hart, Curt (ECY)
Subject: PLEASE REVIEW BLOG RESPONSE TO SJC YOUTUBE VIDEO
Importance: High

Hi, all. Attached is a draft blog item and PowerPoint in response to the YouTube video about Charles Dalton’s property on Orcas. Below is our proposed strategy.

Forgive me for sending to all of you, but I’m not sure who to ask for approval, and it’s important that we post our reply promptly. The YouTube video now has 1,857 views. The Freedom Foundation has it posted on their website, too, http://www.myfreedomfoundation.com/index.php/site/view/friends_of_the_san_juans_offer_justification_for_harassing_local_islander, and the Island Guardian has a short item about it http://www.islandguardian.com/archives/00004240.html .

Strategy:
·         Post the blog on our blog site, link to YouTube.
·         Post a short response on the ChangeWA page referencing our video response.
·         Post PowerPoint with voiceover as a video response. The blog will be the basis for the script.
·         Link to on our FaceBook page with reference to the Friends of the San Juans response: http://www.facebook.com/permalink.php?story_fbid=10150544103742087&id=106592947086

Katie J. Skipper
Communications Manager
Bellingham Field Office
Washington Department of Ecology
Office: 360-715-5205
Cell: 360-510-0682


Tuesday, April 3, 2012

When Is 88 Greater Than 246?

Apologies to my fans for not posting over the last few days.  An accumulation of personal and professional responsibilities diverted my attention. One reader wondered where I had gone. I am here, and I am back with a new CAO riddle.

Question: When is 88 greater than 246?
Answer: When you are discussing Best Available Science for wetlands with a nationally recognized expert.

During the past week, a new controversy arose at our Planning Commission meeting (see previous post) regarding the scientific justification for our buffers. Our County has based its wetland buffer proposal on a paper by Mayer (Mayer et al, 2007). Dr. Paul Adamus, who is an unpaid non-tenured courtesy faculty member at Oregon State, is the "nationally recognized" wetland expert serving as our County consultant. He has been unwavering in his support for the Mayer paper as the basis for our buffer sizes.

One of our local citizens decided to discuss the Mayer paper with Mayer himself. Interestingly, Mayer recommended several other papers that he thought provided equal or greater insight into the workings of buffers.  Mayer also acknowledged that his study had not demonstrated a strong relationship between pollutant removal/retention and buffer width. As Mayer shows in his paper, buffer width explains only about 9% of pollutant removal/retention. Pollutant removal depends 91% on something other than width.

An additional reference recommended by Mayer was a statistical meta-analysis by Zhang, et al., 2009. The Zhang paper is very interesting for several reasons. First, as mentioned, it is a meta-analysis, and we have been told by Dr. Adamus on innumerable occasions that meta-analysis is the best of the best. It's state of the art. It's the kind of analysis performed by epidemiologists. So, the Zhang paper would appear to be in the same category of excellence as the Mayer paper (and remember, Mayer himself is recommending Zhang). Second, the Mayer paper looks at only one pollutant, nitrogen/nitrate, whereas the Zhang paper looks at four: sediment, nitrogen, phosphorous, and pesticides. Third, Dr. Adamus admits that the Zhang paper already is part of the BAS adopted by the County.

One of the major conclusions of the Zhang paper is that buffers, for all practical purposes, have a maximum effective width. At some point, buffer width reaches diminishing returns. Had this principle been incorporated into our County's proposed buffer methodology, we would have ended up with smaller (probably much smaller) proposed buffers. Dr. Adamus acknowledges that he discarded the conclusions of the Zhang paper in favor of the Mayer paper. The question becomes why did Dr. Adamus choose one meta-analysis (Mayer) over another (Zhang)?

The Planning Commission asked Dr. Adamus that question: why Mayer and not Zhang? The answer from Adamus: Mayer used a bigger sample size. Adamus stated this as justification more than once during the Planning Commission meeting.

There are several difficulties with that answer, not the least of which is that it may not be true. The Zhang paper looked at 81 studies for sediment removal, 61 for nitrogen, 52 for phosphorous, and 52 for pesticides. The Mayer study looked at 0 studies for sediment removal, 88 studies for nitrogen, 0 for phosphorous, and 0 for pesticides. If you look at the data across all pollutants, Mayer's sample size was 88 and Zhang's was 246 (81+61+52+52). Mayer's sample size was greater only for nitrogen specifically (88 versus 61). On that basis, Adamus decided to use the Mayer nitrogen results as a proxy for every other pollutant, even though Zhang had actual data for other pollutants.

It's hard to completely fathom Dr. Adamus' answer, and he appears to be suggesting that data quantity trumps data quality too. As a result, not only his conclusion but his entire reasoning about statistical validity may be specious. Data quality and usability are critically important, and there are several acceptance criteria typically employed to evaluate data on those dimensions. They are called the PARCC criteria: precision, accuracy, representativeness, completeness, and comparability. Occasionally, these criteria are supplemented by a sixth criterion, sensitivity.

Sample size, if it has an effect, exerts its influence on these quality criteria, but sample size is not necessarily a worthwhile discriminator in its own right. Did Zhang's smaller nitrogen sample size affect the precision, for example? Actually, for the Zhang paper, the variance of the nitrogen data appears to be smaller than Mayer's, indicating that the Zhang data may be more precise even though it has fewer nitrogen data points than Mayer. Overall, based on a more thorough evaluation of acceptance criteria, Zhang may be the better study to use, even for nitrogen.

Mayer might think so.  That's probably why he recommended it.