Clallam County Director of Community Development Sheila Roark Miller says the Department of Ecology needs to tap the brakes on the Dungeness Water Management Rule. The new rule, which has been under discussion for several years, is set to be formally proposed in March.
Among its more important provisions, the new rule would establish “optimal” flow levels for the Dungeness River, its tributaries and eight independent streams feeding directly to the Strait of Juan de Fuca.
When water levels fall below this established “instream flow,” additional regulatory requirements would be triggered.
Miller said she penned her letter to Ted Sturdevant, Director of the Washington State Department of Ecology, asking for the delay after hearing numerous critical comments from the public during a special session of the County Commission held Tuesday, Feb. 7.
Miller also said she was struck by the recent work of Tom Martin, an engineer who works for the Clallam County PUD, that calls into question the findings of the Instream Flow Incremental Methodology report, the two-decade-old study that produced the data that underlie many of the working assumptions found in drafts of the rule.
“It appears that the data collection methods and accuracy of a scientific study performed in 1988 have come under recent scrutiny,” Miller wrote. “After meeting with Mr. Martin, I agree, based on his evaluation, education, background and his previous experience with FEMA hydraulic engineering studies.”
Miller spelled out other concerns but concluded her letter by asking Ecology to “consider a peer review of the 1991 IFIM report, which will add credibility to both the study and the DOE.”
The validity of the IFIM study was also the subject of a lengthy discussion during the latest meeting of the Local Leaders Water Management Group, held Thursday, Feb. 9, in Sequim. LLWG, a consortium of local organizations, has been working for more than a year to provide recommendations regarding the proposed rule.
Martin, who with Miller serves on the LLWG, again brought up his conclusions. He noted that by reviewing just one portion of the IFIM study he had revised the calculated flow in the Dungeness River during one point of the year from 475 cubic feet per second to 450 — a significant difference, he noted. He called for a further review of the study.
Clallam County hydrologist Ann Soule, another member of the LLWG, also expressed concerns about the IMIF, saying, “People knew how important it was. It surprises me there are errors.”
Cynthia Nelson, watershed lead with Ecology, noted that the department has already spent $1 million on the project, and that reviewing the 1991 document fully would be expensive, and perhaps impossible.
Rather than calling for a complete “re-do,” Soule said it may be possible to do a more limited review to see if a full review is necessary. “An IMIF is a multi-year, multi-million dollar project,” she said.
Gary Smith, who chairs the committee, said he also believes a new set of eyes might be valuable. “I think it’s worth an independent review. There is nothing more important than the science and the confidence of the people in the science.”
Dr. Hal Beecher, instream flow specialist for the Washington Department of Fish and Wildlife and a leader in creating the original study, was hesitant to agree to the call for a new study, or a full review of the 1991 IFIM. “What are the questions? What are the issues?”
“I think it’s a fairly major task. I don’t have any idea what the costs would be,” Beecher said.
Citing the logistical difficulties of pulling together the original materials, Beecher said, “It’s almost easier to re-do it, starting with the field work. And we could spend a lot for the same results.”
Beecher added that he has sufficient trust in the study to move forward.
Martin suggested that it might be useful simply to review a second section of the study to see if the errors he found in his review of one section were repeated, Beecher said Martin’s suggestion “makes sense.”
The committee agreed to call for a review, but the issue remains largely unsettled.
Ann Wessel, instream flow rules coordinator with Ecology, asked Smith, “Who will pay for it?”
Smith agreed that “If there’s no money, it won’t get done.”