Posted: November 4, 2011
Birds do it. Iced tea may do it. But, do we need to do it?
More About Stormwater
Learn more about the FC regulations at the November 22, 2011 meeting of the Manufacturing Industrial Council of Seattle. The meeting will include presentations by technical and legal experts beginning at 4 pm. Call Dave Gering for details, 206-762-2470.
Few things in the animal kingdom are more universal than the production of fecal coliform, a bacterium produced by every known warm-blooded creature that eats.
But when it comes to cleaning up fecal coliform (FC), the universe shrinks to a small but growing number of private business and public agencies. This year they became responsible for monitoring and managing FC runoff in the storm water that washes from their properties into “303D” waterways.
These are waterways which are impaired by pollution. Our state’s 303D list includes just about every body of water that can be seen from the observation deck of the Space Needle, including the Duwamish River and Elliott Bay where about 80 companies and a few public agencies are subject to new state FC regulations.
And why not? FC carries nasty pathogens that can make people sick and even when the FC pollution level is not dangerous, the whole concept is disgusting.
But while the regulations are based on good intentions, implementation is fraught with challenges and liabilities.
One compliance challenge arises from the fact FC is a living organism.
Unlike heavy metals, chemicals or most other pollutants, FC grows. It dies. It ebbs. It flows. It all depends on changes in temperature and other variables. That can make it hard to determine if the FC levels found at a testing lab are the same as those at the location where the FC sample was collected.
FC also enters our world in a wide variety of ways.
While human beings are major generators, so are animals and, on a pound-for-pound basis, some creatures are higher FC producers than humans, including dogs.
So are seagulls, ducks and geese which continue to bomb away over waterways regardless of what regulations humans create for the shorelines.
FC is also created by plant material including those hay bales that are used to control stormwater runoff at construction sites. Tests show they produce gobs of FC.
In fact, when land use is examined collectively, industrial areas are relatively low FC producers. Retail areas are worse than industrial ones and residential areas are worse than retail. Worst of all are natural open spaces with their greatest concentrations of flora and fauna.
For all these reasons, it makes abundant good sense to be aware of and try to control fecal coliform along beaches in water bodies such as Lake Washington or Green Lake where people swim and might even gulp down occasional mouthfuls of water.
But, do such efforts make sense in the Duwamish River? Or in Elliott Bay? Really?
It should surprise no one that Seattle Industry would pose such questions, but last summer very similar questions were raised by a slew of former environmental regulators in a prominent and provocative article in the Seattle Times. You can read the article here.
According to the article, the City of Seattle and King County utility ratepayers are now being asked to pony up about $1.3 billion to stop raw sewage from pouring into local waterways during heavy rainstorms that overwhelm combined sewer-storm drains.
These overflows discharge nearly one billion gallons of raw sewage into King County waters every year and for many of our political leaders it is an article of faith that the overflows must end. In historic terms, the perspective dates back at least to the 1950s and the Metro clean-up of Lake Washington led by legendary civic leader Jim Ellis.
But in the Times, the sacred cow strategy of complete clean up was skewered by former environmental managers for the City of Seattle, King County and the federal Environmental Protection Agency. According to the Times article by award-winning reporter Lynda Mapes, these experts believe the idea is flat-out wrong-headed.
They say it would be wiser to focus on sewage that poses the most danger to people, while reserving other public resources to address environmental issues that are more significant.
Make no mistake about it - one billion gallons is a lot.
But sewage overflows throughout the county used to total 20 billion gallons per year and the remaining overflows are no longer considered significant threats to the environmental health of Puget Sound. Far greater threats are posed by run off from residential and commercial areas, freeways, farms, livestock, pets, birds and other pollutants.
Former US EPA Director Bill Ruckelshaus was among those quoted in the article. According to Mapes, he said of the clean-up plan: “This is just crazy. We don’t have unlimited funds in this country, and whatever we do, we ought to spend where we get the most bang for the buck … cost-benefit has not been part of the discussion.”
Kevin Clark, a former manager of Seattle Public Utilities, told Mapes he originally supported the concept of total clean up because “I just wanted something I could explain to the newspapers. One everywhere was nice and simple.”
Now, Clark says “I am all for asking if capturing the last few overflows is the best use of limited public money. We ought to have a big old rousing debate. There is a tremendous amount of money being spent on this. Are we getting the best bang for the buck?”
Which brings us back to the Duwamish.
The Duwamish drains nearly half of all the raw sewage that overflows throughout the county during heavy rain storms, with much of the muck entering Elliott Bay.
For all these and other good reasons, the Duwamish and Elliott Bay are not good places to swim or drink water, and if anyone does either one, we’ve personally never seen it happen.
So, as the former regulators ask, why waste so much public money that could get so much better bang-for-the-buck someplace else? And, why should the shoreline property owners and managers be subject to the new FC regulations?
Violations of the FC regs can be punished by fines up $10,000 per day, potential jail time and liability for financial damages from civil suits.
Seattle Industry will continue to track this issue in the future. For now we leave with this metamorphic food for thought.
In the mid 1990s, the nation experienced a brief but intense news media flare-up over test results in the Midwest that found FC in the ice tea served at some restaurants. The furor died when no one could produce even one tea drinker who suffered any type of harm.
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