Oh The Humanity!

This is an example of an environmental problem that County staff evidently feels is so severe and demonstrative that they had to obtain photographic evidence and send it to three consulting CAO wetland scientists under contract to the county.

Ever get that feeling that somebody's watching you (and your downspouts)?

From: Shireene Hale [mailto:shireeneh@co.san-juan.wa.us]
Sent: Wednesday, February 02, 2011 2:52 PM
To: Amanda Azous; Dan Nickel; 'Paul Adamus'
Subject:

Attached is a photo taken by one of our staff in Lopez Village showing grass around downspouts killed by something, likely in runoff from the roof.

Shireene Hale, EHS

Planning Coordinator/ Deputy Director

San Juan County Community Development & Planning

PO Box 947

135 Rhone Street

Friday Harbor, WA 98250

360.370.7569

shireeneh@sanjuanco.com

Buffer Paradox

Why is the science about buffers so poor (see email below), and yet they are proposed with calculated precision as a solution for all manner of pollutants? For such a "well accepted" remedy to pollution, you'd think there would be all sorts of data about the effectiveness of buffers to clean up metals, pesticides, herbicides, and other chemicals.

The answer is that, outside of their use by planners and wetland scientists, buffers have no reputation as a remedy for pollution. That's why they have been studied so little. No one in the venerable fields of ecotoxicology or fate & transport would propose a buffer as the primary solution to contamination. If buffers were effective as a remedy, then to clean up Hanford, Love Canal, Times Beach, or the Duwamish, all we would have to do is put a buffer around them and call it a day.

There is plenty of data about the ecotoxicology and fate & transport of thousands of potential contaminants. If there is nary a mention about buffers in that scientific literature, it is probably for the same reason there is no mention of buffers as a solution to AIDS: buffers have no relevance to the problem.

Buffers simply are not useful as a remedy for authentic pollution problems. From my perspective, they are a planning gimmick. If we want buffers, we should have them for aesthetic or public policy reasons.

______________________________________________________________

From: Paul Adamus <adamus7@comcast.net>

Date: September 29, 2011 9:29:01 AM PDT

To: Shireene Hale <shireeneh@sanjuanco.com>

Subject: Alderton comments - reply

Shireene,

Sorry I could not reply to this before the meeting.  Janet Alderton raises some good points with regard to the minimum width of buffer that should be allowed - in the specific case of protecting functions of the wetlands of lowest importance from low-intensity development where the potential for pollutant transport is low.

I concur with her observation that there is almost no published peer-reviewed literature on the adequacy or inadequacy upland buffers for removal of soluble pollutants such as nitrate within the width category of 0 to 82 feet (0- 25m).  As Mayer et al.  (2007) noted, "Effectiveness was not related to buffer width when analyzing buffers within width categories."  [emphasis added].   I chose a 15 foot threshold based not on nitrate removal, but on removal of runoff-borne sediment because published literature amply demonstrates that vegetated buffers of even less than 15 feet are effective for filtering that from runoff.  I do not suggest that sediment is necessarily a good proxy for nitrate, but it is the only data we have.  Note that the 15 foot minimum we proposed is close to the 25 foot minimum buffer width for protecting wetlands recommended by the Washington Department of Ecology.  However, unlike our approach, Ecology's buffer width recommendation does not explicitly address situations where potential for pollutant transport is low, as is the only case where our 15 foot buffer would be applied.

I also concur with Janet Alderton's observation that the removal of nitrate might not be a good proxy for removal of other soluble pollutants such as some surfactants.  However, there is essentially no literature on the effectiveness of buffers for reducing surfactants, so we are forced to adopt a best-available science approach based only on nitrate and sediment removal.

Paul

BAS Ackwards

Why don't basketball players wear football helmets? The answer is that there is no need. There are few, if any, concussions in the NBA. Yes, there might be the occasional elbow to the head, but the risk of a serious head injury is considered to be de minimis. There just aren't enough serious head injuries in the NBA to warrant concern.

Now suppose a determined helmet maker wants to increase his sales, and he seizes upon the idea of selling football helmets to the NBA. He discovers that, compared to the NFL, there is a frightening absence of head injury data in the NBA. This is disturbing since the helmet maker really believes that serious head injuries are ubiquitous in sports. He makes a sales pitch to the NBA where he characterizes the NBA's lack of data about harm as being a genuine cause for concern, and he proposes that every player wear a helmet, to be precautionary in the face of the NBA's scientific uncertainty.

Ah, but some trouble makers challenge the helmet maker over the need for NBA players to wear helmets, so the helmet maker responds by trotting out Best Available Science (BAS) about helmets.  The BAS shows that helmets reduce injuries to professional athletes by a significant amount. The NBA finds the science to be very persuasive, and as a result, it decides that all of its players must wear football helmets from now on.

What went wrong here? Can you spot the syllogistic errors that led to pointless (and expensive) safety measures being taken for a situation that was already de minimis? For one, the salesmen's BAS is about helmets, not the risk situation in the NBA. In fact, to make his pitch, the salesmen never needs to know the actual risk to NBA players. He only needs to be persuasive about head injuries being ubiquitous, point out that the NBA lacks data on this ubiquitous problem, and then propose a plausible solution ... his helmets.

That brings us to San Juan County where expanded buffers (i.e., helmets) are being proposed for our wetlands, streams, and shorelines. Despite data showing many positive aspects to our ecosystem, there is an absence of data showing no harm. We are told by authorities that pollutants are ubiquitous, and many citizens and officials tell frightening stories about our ecosystem's dire prospects if we don't do something. The proposals for much bigger buffers are justified by BAS about buffers, not BAS about the county.

I believe this misconstrues BAS, and it allows the buffer scientists to flip the CAO process on its head. The scientists aren't using BAS about San Juan County to design buffers; they are using BAS about buffers to design the county.

When that happens, buffer scientists become little more than buffer salesmen and BAS becomes just a sales brochure for the salesmen's latest product. Like all pitchmen, the buffer salesmen would love to see you kitted out in the deluxe model.