2012 is a wrap and here’s to looking forward to what the year to come will bring to the shared waters of the Salish Sea. But before we jump, take a look back at some top news items of the past year:
Coal takes lumps. Thousands came to stand up and speak out their concerns at scoping meetings about the negative environmental impacts the coal export facility proposed for the Cherry Point Aquatic Reserve will have on the local, regional and international land and waters— while outnumbered project proponents chanted their one-note mantra of ‘jobs, jobs, jobs’
No ‘smoking gun.’ It cost $26 million and 150 witnesses to lead Judge Bruce Cohen to report in three volumes that the precipitous decline in Fraser River sockeye was due to a multiplicity of causes and to recommend 75 actions that should be taken to remedy the decline.
‘People’ sunk. A little over a year after founder and executive director retired from People For Puget Sound, new management laid off staff, failed to fundraise, blew through cash reserves and unilaterally closed down the 21-year old environmental group.
Sound declines. Former U.S. Army Corps of Engineers Colonel Tony “Embrace-The-Porcupine” Wright took over the helm of the Puget Sound Partnership and reported that most indicators show the Sound still in decline but that things could be much worse.
Elwha love. With most of the Glines Canyon Dam blasted away, the Elwha River again runs free and begins unloading tons of silt down to the Strait.
Bag bans. Following the city of Edmonds’ earlier example of banning plastic shopping bags, the cities of Bellingham, Seattle, Issaquah, Port Townsend, Mukilteo and Bainbridge followed suit.
Victoria flushes. Despite protests from misguided academics, opportunistic pols and some recalcitrant municipalities, the Capital Regional District moved forward with financing and planning to build (finally) secondary sewage treatment for Victoria
Big drink. Tethys Enterprises acquired 30 acres within the Anacortes city limits which allows the city to provide the bottling company’s proposed one million-square foot plant with up to 5 million gallons of Skagit River water per day.
Ocean acid. The threat of ocean acidification to the shellfish industry and the marine food web was elevated by a state panel’s report with several recommendations, including the recommendation that the state must advocate for regional, national and international policies to reduce carbon-dioxide emissions.
Alive and well. Springer, the orphan killer whale found near Vashon in 2002, nursed back to health and jetted back to her Northern resident family, was feted with a 10th anniversary celebration and again declared an ongoing success story of international cooperation.
Tribal power. Tribes and First Nations began campaigns against social and environmental damages anticipated from major oil and coal export projects north of the Salish Sea by Enbridge near Kitimat, by Kinder Morgan in Vancouver, and by SSA Marine at Cherry Point, Washington.
Estuary revival. 4,000 acres of tidelands at the northern end of Port Susan Bay in Snohomish County were finally connected to Puget Sound by The Nature Conservancy of Washington in partnership with state and federal agencies and the Tulalip Tribes.
(Details on the above news stories are found in 12 months of Salish Sea News and Weather postings)
Looking to 2013:
Tim and Tom game. Despite Democratic Party victories in Washington state, turncoat Democrats Tim Sheldon and Rod Tom joined Republicans to allow Republicans to seize control of the State Senate. We’ll have to see how that affects how environmental legislation comes before the Senate and how that affects the budgets for environmental programs, including those of the Puget Sound Partnership. Traitors like Tim and Tom give credence to the adage of not trusting men with two first names.
Fuel futures. Not much action on the Gateway Pacific Cherry Point facility proposal until the draft Environmental Impact Statement is issued but watch what the coal export market is doing and the jockeying for first position among multiple Northwest port proposals. Also watch the growing future of exporting liquified natural gas (LNG) and how the Puget Sound refineries bring more crude oil in by rail.
Acid trip. The state’s taken the first step in saying what needs to be done about slowing ocean acidification. Now what?
-- Mike Sato
Monday, December 31, 2012
Monday, December 24, 2012
Aloha, Senator Dan
First Lt. Daniel Inouye (Wikimedia) |
Senator Dan, who serve in the Senate for nearly 50 years, died last week and received many accolades for his service to the country as soldier and senator. He had lost his right arm in the Second World War and I recall how firmly he shook my hand using his left hand.
I don’t know if I’d have passed muster and become the kind of man to make my state and nation proud. I think about sitting before the Selective Service draft board whose members all looked like the served alongside Senator Dan and even looked like him, telling them the Vietnam War was immoral and how I couldn’t in good conscience go to their war.
But I admired Senator Dan and I cheered when he impassively grilled President Nixon’s Watergate conspirators and I got mad when one of them called him “that fat Jap” not knowing the microphone was live.
He become more and more “senatorial” and demonstrated that kind of majestic dignity in chairing the Iran-Contra Senate hearings. Go, Senator Dan; we got close but just couldn’t get Reagan, the true Teflon president.
Senator Dan got older and I guess I did, too. I got disgusted when he threw his seniority around and supported Senator Ted Stevens of Alaska on oil drilling and oil tankers, putting the environment I love at risk and calling Senator Stevens, “my good friend Ted Stevens.” I had never thought of Alaska and Hawaii as sharing political interests simply because we’d entered the United States as its 49th and 50th states.
I think 50 years is too long to be in office but that’s the way the Senate rules work and that’s what the voters in Hawaii wanted. Senator Dan’s passing made me reflect on who else I’ve been traveling with from back in the early ‘60s. For me, I guess that’d be limited in longevity to Bob Dylan.
So, now it’s me and Dylan. Aloha, Senator Dan.
--Mike Sato
Wednesday, December 19, 2012
Yes, Virginia, There Is A Santa Claus
December 18, 2012
NEWS RELEASE
FOR IMMEDIATE USE
Contact: Asha Lela, Islanders for a San Juan Islands National Monument 360-468-2838
SANTA JOINS IN SUPPORT FOR SAN JUAN ISLANDS NATIONAL MONUMENT
(San Juan Islands, Washington) Santa added his name to the list of supporters seeking a presidential proclamation to protect 1000 acres of Bureau of Land Management lands in Washington State’s San Juan Islands.
“We wrote to Santa asking his help in protecting these lands in perpetuity as a national monument,” said group leader Asha Lela of Islanders for the San Juan Islands National Conservation Area. Elected officials, hundreds of businesses, and thousands of individuals have asked the President to proclaim the BLM lands in the islands as the San Juan Islands National Monument.
Santa took time out of his busy schedule to reply to the group’s note:
“My elves aren’t equipped to handle national monuments. President Obama is the person for this. I sent him a note. Here’s a copy. Good luck!”
(Note attached.)
Check out updates on the campaign for the San Juan Islands National Monument here.
# # #
NEWS RELEASE
FOR IMMEDIATE USE
Contact: Asha Lela, Islanders for a San Juan Islands National Monument 360-468-2838
SANTA JOINS IN SUPPORT FOR SAN JUAN ISLANDS NATIONAL MONUMENT
(San Juan Islands, Washington) Santa added his name to the list of supporters seeking a presidential proclamation to protect 1000 acres of Bureau of Land Management lands in Washington State’s San Juan Islands.
“We wrote to Santa asking his help in protecting these lands in perpetuity as a national monument,” said group leader Asha Lela of Islanders for the San Juan Islands National Conservation Area. Elected officials, hundreds of businesses, and thousands of individuals have asked the President to proclaim the BLM lands in the islands as the San Juan Islands National Monument.
Santa took time out of his busy schedule to reply to the group’s note:
“My elves aren’t equipped to handle national monuments. President Obama is the person for this. I sent him a note. Here’s a copy. Good luck!”
(Note attached.)
Check out updates on the campaign for the San Juan Islands National Monument here.
# # #
Tuesday, December 18, 2012
Pay-To-Read —What?
The McClatchy-owned newspapers in Puget Sound (The News Tribune of Tacoma, The Olympian and the Bellingham Herald) are all going to require paid subscriptions beginning this week to read their online content. Just like the big boys Wall Street Journal and The New York Times and just like the small time Skagit Valley Herald and Vashon-Maury Island Beachcomber.
Owner and publisher Mark Owings of the Bellingham Herald describes the change this way: “Now, it's never fun to ask anyone to pay for something that has been free. But providing unlimited access across all platforms for a small amount makes sense. It also gives us the ability to protect our most valuable product -- our content. I know it really doesn't need to be said, but I'll say it anyway -- a business that gives away its most valuable product for free is doomed.”
The “small amount” for online access begins at an additional 46-cents a week for print subscribers when they renew and an “introductory rate” of 99-cents a month ($69.99 a year) for online-only subscribers.
Let me rephrase Mark Owings’ dictum this way: “A news medium that doesn’t provide its most valuable product — its content— is doomed.”
At the end of October, USA TODAY reported: “The Wall Street Journal kept its position as the No. 1 newspaper. Its average circulation grew 9.4% to 2.3 million. USA TODAY was second at 1.7 million, followed by The New York Times at 1.6 million. Circulation at the Times grew 40% from a year ago. More than half of the Times' circulation was for digital editions.”
Now, by comparison, the average weekday circulation of the Bellingham Herald is 16,154. The Olympian’s average weekday circulation is 21,876 and the News Tribune of Tacoma’s is 74,826. By comparison, the Seattle Times’ weekday average is 221,665. (Alliance for Audited Media, 6 months ending Sept. 30, 2012)
The joke around our house is that the Monday Bellingham Herald is so light and small that if the wind’s blowing hard, go look for it in the bushes or in the street. But our household subscribes seven days a week— because we like newspapers, even when we have to search down the street to recover them.
The interesting, local news content at the Herald and The Olympian keeps getting less and less as news staffs get smaller and smaller. The bitter irony in news media has been the understanding that advertising dollars pay news salaries. Advertisers advertise because people buy newspapers. People buy newspapers to read the news. Less news to read or more news read, watched or listened to elsewhere— less readers of newspapers. Less advertisers, less revenue, good-bye newspapers.
The revenue generated by subscriptions is real money but not what makes a paper profitable. In the old days when there were service stations or even now with the gas’n’go mini-marts, the real profit doesn’t come from the gas that’s sold but from the tires, batteries and accessories that the service stations of the past sold and the beer, gum and cigarettes today’s mini-marts sell.
What’s sad about Mark Owings’ and McClatchy’s decision to charge for online content is that you will now pay for something you once got for free— without much difference in added value. Somewhat like once being able to use a public toilet for free and now having to pay a quarter to use the same toilet.
It should be instructive for Mark Owings and McClatchy management to take a good look at the reasons for the growth in The New York Times digital circulation. One reason is the aggressive marketing of its enhanced content. The other is the enhanced content itself, the breaking news, the multi-media presentations and background information that subscribers to the print-only newspaper don’t get.
That makes your online content valuable— and worth paying to read.
--Mike Sato
Owner and publisher Mark Owings of the Bellingham Herald describes the change this way: “Now, it's never fun to ask anyone to pay for something that has been free. But providing unlimited access across all platforms for a small amount makes sense. It also gives us the ability to protect our most valuable product -- our content. I know it really doesn't need to be said, but I'll say it anyway -- a business that gives away its most valuable product for free is doomed.”
The “small amount” for online access begins at an additional 46-cents a week for print subscribers when they renew and an “introductory rate” of 99-cents a month ($69.99 a year) for online-only subscribers.
Let me rephrase Mark Owings’ dictum this way: “A news medium that doesn’t provide its most valuable product — its content— is doomed.”
At the end of October, USA TODAY reported: “The Wall Street Journal kept its position as the No. 1 newspaper. Its average circulation grew 9.4% to 2.3 million. USA TODAY was second at 1.7 million, followed by The New York Times at 1.6 million. Circulation at the Times grew 40% from a year ago. More than half of the Times' circulation was for digital editions.”
Now, by comparison, the average weekday circulation of the Bellingham Herald is 16,154. The Olympian’s average weekday circulation is 21,876 and the News Tribune of Tacoma’s is 74,826. By comparison, the Seattle Times’ weekday average is 221,665. (Alliance for Audited Media, 6 months ending Sept. 30, 2012)
The joke around our house is that the Monday Bellingham Herald is so light and small that if the wind’s blowing hard, go look for it in the bushes or in the street. But our household subscribes seven days a week— because we like newspapers, even when we have to search down the street to recover them.
The interesting, local news content at the Herald and The Olympian keeps getting less and less as news staffs get smaller and smaller. The bitter irony in news media has been the understanding that advertising dollars pay news salaries. Advertisers advertise because people buy newspapers. People buy newspapers to read the news. Less news to read or more news read, watched or listened to elsewhere— less readers of newspapers. Less advertisers, less revenue, good-bye newspapers.
The revenue generated by subscriptions is real money but not what makes a paper profitable. In the old days when there were service stations or even now with the gas’n’go mini-marts, the real profit doesn’t come from the gas that’s sold but from the tires, batteries and accessories that the service stations of the past sold and the beer, gum and cigarettes today’s mini-marts sell.
What’s sad about Mark Owings’ and McClatchy’s decision to charge for online content is that you will now pay for something you once got for free— without much difference in added value. Somewhat like once being able to use a public toilet for free and now having to pay a quarter to use the same toilet.
It should be instructive for Mark Owings and McClatchy management to take a good look at the reasons for the growth in The New York Times digital circulation. One reason is the aggressive marketing of its enhanced content. The other is the enhanced content itself, the breaking news, the multi-media presentations and background information that subscribers to the print-only newspaper don’t get.
That makes your online content valuable— and worth paying to read.
--Mike Sato
Monday, December 17, 2012
God and Guns
I don’t know how many of you said a prayer when you heard the horrific news last Friday from Sandy Hook Elementary School in Newtown or said a prayer on Sunday if you went to church.
I felt a huge tear in the moral fiber of our society on Friday and had to stop watching, reading and listening to the news.
The mayor of Newtown early on was quoted as saying “evil came to Newtown.” I don’t see “evil.” What I see and what angers me is, what kind of God allows children to be murdered? In Sandy Hook Elementary School. In Afghanistan. In Africa. In homes in cities, town and villages around the world.
If the God you prayed to on Friday and Sunday is, as holy books like to say, omniscient, omnipresent and omnipotent, He is as cruel and capricious as Hamlet’s gods, who “kill us for their sport.” If He is not omniscient, omnipresent and omnipotent, there is no supernatural “evil” that visited Newtown to stands outside God’s supernatural “good.”
Instead, we suffer again an all-too-human moral failure. A failure to make it harder for a murderer-- sane or insane-- to find and use the kind of semi-automatic weapon that make it possible to kill and maim so many so quickly, this time young children.
If the past is any indication of the future, murders with weapons like these will continue because there will continue to be access to weapons like these in America. There will be those who will blur the distinctions among guns and rifles and we will hear the mantras: “Guns don’t kill, people kill.” “When guns are outlawed, only outlaws will have guns.”
Best then to make sure that every school administrator and teacher, every mall operator and merchant, every theater owner and usher— those responsible for every public space-- be required to have and be trained in emergency shutdown procedures to reduce the carnage from murderous situations.
That’s the society we’re living in and we need to watch out for each other and our children. Because God isn’t— and because there are many who believe it is their God-given right to have the very kinds of weapons that commit mayhem and murders.
--Mike Sato
I felt a huge tear in the moral fiber of our society on Friday and had to stop watching, reading and listening to the news.
The mayor of Newtown early on was quoted as saying “evil came to Newtown.” I don’t see “evil.” What I see and what angers me is, what kind of God allows children to be murdered? In Sandy Hook Elementary School. In Afghanistan. In Africa. In homes in cities, town and villages around the world.
If the God you prayed to on Friday and Sunday is, as holy books like to say, omniscient, omnipresent and omnipotent, He is as cruel and capricious as Hamlet’s gods, who “kill us for their sport.” If He is not omniscient, omnipresent and omnipotent, there is no supernatural “evil” that visited Newtown to stands outside God’s supernatural “good.”
Instead, we suffer again an all-too-human moral failure. A failure to make it harder for a murderer-- sane or insane-- to find and use the kind of semi-automatic weapon that make it possible to kill and maim so many so quickly, this time young children.
If the past is any indication of the future, murders with weapons like these will continue because there will continue to be access to weapons like these in America. There will be those who will blur the distinctions among guns and rifles and we will hear the mantras: “Guns don’t kill, people kill.” “When guns are outlawed, only outlaws will have guns.”
Best then to make sure that every school administrator and teacher, every mall operator and merchant, every theater owner and usher— those responsible for every public space-- be required to have and be trained in emergency shutdown procedures to reduce the carnage from murderous situations.
That’s the society we’re living in and we need to watch out for each other and our children. Because God isn’t— and because there are many who believe it is their God-given right to have the very kinds of weapons that commit mayhem and murders.
--Mike Sato
Wednesday, December 12, 2012
Hell or High Water? High Water, King Tides.
Port Orchard (PHOTO: Ray Garrido/Ecology)
|
“Next week we will be having very high tides in Puget Sound.
“If you want to see some dramatic stuff going on, check out the Duwamish on the 14th-17th early in the mornings.
"NOAA is predicting 12 foot plus tides. If the weather is bad, i.e. low pressure over the city then add another foot or two, and if the river is really flowing and a few more inches in the waterway.
“Look over at the T105 park for inundation, or the little Diagonal Ave. park. T105 should be more dramatic I think. We are watching the marinas down there too. If the bad weather holds the marina floats will be coming close to mechanical limits.”
And, from the Department of Ecology, heralding the “King Tide” season:
* Along Washington's outer coast, king tides will occur Dec. 12-15, 2012, and Jan. 10-12, 2013.
* In the Strait of Juan de Fuca, they occur Dec. 12-14, 2012, and Jan. 8-12, 2013.
* The Puget Sound dates for king tides are Dec. 16-19, 2012, and Jan. 14-17, 2013.
Locate the highest tides— and take and share your photos:
* Use Ecology's king tide map and schedule to find when and where the highest tides will occur.
* Locate a public beach by checking out Ecology's Coastal Atlas.
* Take photos during a king tide, preferably where the high water levels can be gauged against familiar landmarks such as sea walls, jetties, bridge supports or buildings.
* Note the date, time and location of your photo - then upload your images on the Washington King Tide Photo Initiative Flickr Group.
Stay dry, ducklings.
--Mike Sato
Tuesday, December 11, 2012
When You Go To Seattle, Wear Coal Dust In Your Hair
Child coal miners-1908 (Wikimedia Commons) |
Interested in giving verbal comments on the coal export facility proposed for the Cherry Point Aquatic Reserve when public meetings are held Tuesday in Vancouver, WA, and Thursday in Seattle? Take a number to enter random drawings for about 150 two-minute speaking slots at each event. The drawings will occur at the start of each hour during the three-hour public meetings. People can enter the drawings at any time before the final drawing. Drawings set for spoken comments at upcoming meetings for proposed Gateway Pacific
From verbal comments offered at past public meetings, it seems clear that it’s a free country and people can say whatever they want short of shouting “Fire!” However, project supporters hadn’t seemed to get the point of this comment period: the comments are meant to address what things the government agencies should include to be examined in the draft Environmental Impact Statement for this project.
Project supporters are all smart people so I won’t do their work for them but speakers saying ‘jobs jobs jobs’ one after another don’t move the process forward, it just makes it dumb and boring. I’ve been much more impressed by the pre-meeting work done by organizers against the coal project who have held workshops and training sessions on how to make comments that express both a position on the coal project and a substantive issue that needs to be examined in the dEIS. They’ve maintained that discipline in the public meetings thus far, including a firm reminder to participants that the views of opponents should be respected and the differences of opinions not made personal.
Project supporters can do the same, I’m sure.
Before today’s meeting in Vancouver and Thursday’s meeting in Seattle, here are a couple more news items to draw from in providing comments on the coal export proposal:
What is the risk factor of human error or natural disaster in causing a major spill of coal in the loading and transporting process?
A large bulk carrier docking at Westshore Terminals in Roberts Bank destroyed a coal conveyor system early Friday morning, knocking out the largest of the port’s two berths and spilling an undetermined amount of coal into Georgia Strait... The mishap happened at 1 a.m. when the bulk carrier Cape Apricot, with a capacity of 180,000 tonnes, slammed into a trestle, the only link between the berth and the terminal, destroying more than 100 metres of it. The ship went right through the causeway, taking a road, the coal-carrying conveyor belt, and electric and water lines with it. Ship crashes into dock at Westshore Terminals, spilling coal into water (with video)
How many more minutes will more coal train traffic block roads?
A Burlington Northern Santa Fe train is no longer blocking three major intersections in Mount Vernon, according to city police. The train blocked several roadways, including Fir Street, College Way and Riverside Drive, for 45 minutes to an hour, said Sgt. Peter Lindberg. The train was moved about 10:45 a.m. “It’s an emergency brake situation,” Lindberg said when the train was stopped. “That’s all we know and (BNSF) is not getting back to us because they are probably busy.” Train in MV no longer blocking roadways
Like many other cities, Seattle, Edmonds and Marysville are alarmed at the prospect of massive coal trains and their effects on communities. Compounding it all, tracks are already reaching capacity or nearing it. Coal train impacts feared along the Sound
How much will the coal to be exported from Cherry Point contribute to global warming and sea level rise?
As recovery continues from Superstorm Sandy, the U.S. government reports Thursday that flooding from future storms will likely worsen as global sea levels rise between 8 inches and 6.6 feet by the end of this century. NOAA sees sea level rise of up to 6.6 feet by 2100
Go get ‘em, tigers.
--Mike Sato
Sunday, December 9, 2012
This is Regulatory Reform?
In earlier blogs, I’d alerted readers to how the Department of Ecology is proposing a makeover of the State Environmental Policy Act (SEPA) provisions to exempt development actions requiring environmental review. Tomorrow, December 11, is the final day to comment on the rule makeover:
“In the first of a two-part rulemaking, the Washington Department of Ecology is proposing changes to the State Environmental Policy Act which would, among a number of changes, give local governments the option to select the exempt threshold for single-family housing developments from between four to up to 30 units. For multi-family buildings, local governments could select from four to up to 60 units as the exempt level while the threshold for minor agricultural construction projects could be between 10,000 to 40,000 square feet. The public comment period for the proposed rule is open until Dec. 11. Ecology seeks public comment on draft SEPA rule changes ”
SEPA is not a perfect tool to require environmental review of residential and multi-family development but it provides a way for the public to comment on development actions and to appeal governmental actions, if appeal is warranted. Raise the threshold to make projects exempt from SEPA may make life easier for developers and government jurisdictions but at the expense of public oversight.
Our man on the Peninsula Al Bergstein has written to the Department of Ecology objecting to this proposed change in exemption levels, and Al and I encourage you to do the same and email your comments by COB Tuesday.
“In the first of a two-part rulemaking, the Washington Department of Ecology is proposing changes to the State Environmental Policy Act which would, among a number of changes, give local governments the option to select the exempt threshold for single-family housing developments from between four to up to 30 units. For multi-family buildings, local governments could select from four to up to 60 units as the exempt level while the threshold for minor agricultural construction projects could be between 10,000 to 40,000 square feet. The public comment period for the proposed rule is open until Dec. 11. Ecology seeks public comment on draft SEPA rule changes ”
SEPA is not a perfect tool to require environmental review of residential and multi-family development but it provides a way for the public to comment on development actions and to appeal governmental actions, if appeal is warranted. Raise the threshold to make projects exempt from SEPA may make life easier for developers and government jurisdictions but at the expense of public oversight.
Our man on the Peninsula Al Bergstein has written to the Department of Ecology objecting to this proposed change in exemption levels, and Al and I encourage you to do the same and email your comments by COB Tuesday.
December 7, 2012
Department of Ecology
ATTN: Fran Sant
PO Box 44703
Olympia, WA 98504-7600
To Whom It May Concern:
I am writing to comment on the proposed SEPA rule changes, as documented in October 2012.--Mike Sato
I am writing to strongly object to the proposed changes to the SEPA rules, as they pertain to the following sections:· Proposed changes to WAC 197-11-800(1)
o I strongly oppose establishing separate flexible thresholds for local governments as laid out in the following sections.
§ Section 1 b i and ii
· This change appears to significantly weaken environmental protections by exempting local counties for projects of what is arbitrarily determined by Ecology to be ‘significant’. There is no supporting information about how these sizes of projects were scientifically formulated, nor any basis for believing they will beneficial to the environment or not.
§ Section iii of same
· Additionally, this seems to be an arbitrary size, that does not scientifically establish whether a single project may do significant harm to a local environment.
§ Section iv of same
· Again, these sizes of projects being exempted do not seem to have any supporting scientific backing to establish why these exemptions are deemed appropriate.
§ Section C level iii
· The idea of 21 days to challenge significant changes to the rules changes on a local basis puts too high a burden on what are usually underfunded local citizens, their governments and interested organizations. Often these groups meet monthly, and establishing a 6 week timeframe seems to be more in tune with allowing citizens to have adequate time to prepare a challenge to a rule.
§ These rule changes in the table could just as easily been substantially larger or smaller, as there is no scientific understanding why these numbers were chosen.
As a bureaucracy that is charged with bringing a scientific point of view to the process of protecting our common environment, we of the public rely on the Department of Ecology to use Best Available Science (BAS) in making these decisions. By not substantiating these rules changes by using BAS, the Department puts themselves, and the taxpayers that fund them, at substantial risk of a challenging (and costly) lawsuit. Courts have ruled over and over again in the last decade that BAS is a standard as a credible method of making environmental rules, especially in supporting challenges to the State’s Shoreline Master Program and Critical Areas Ordinances.
As a person who is working on a variety of issues, including currently being a member of the Jefferson County Marine Resource Committee, edit the Olympic Peninsula Environmental News, and have been a working member of the Jefferson County Shoreline Management Program, Citizen Advisory Group, I support holding off making these changes (while going ahead with the others in this rules change), in order to produce credible evidence that these changes will not harm the environment.
Sincerely,
Al Bergstein
Member - Jefferson County Marine Resource Committee
Member – Strait ERN – Puget Sound Partnership
Jefferson County
1607 Admiralty Ave.
Port Townsend, WA 98368