Tell Ecology: Save Water, Save Money

Comments due May 10, 2019


Online comment portal here. Use language in "What you can do" below for your comment.

It started with one court decision, in one county, concerning one river in Whatcom County. But it sent ripples outward that shook how all of Washington State would plan to balance water for salmon, agriculture, and a growing population across many watersheds.
 
Background

A case that came out of the State Supreme Court in 2016 with Whatcom County and the State Growth Board (also known as the “Hirst decision”) found that Whatcom County was allowing rural development without first verifying if water was available. This case had implications across the state as many counties were also relying upon Department of Ecology’s water rights exemption for private rural domestic wells as a source of water. 

In 2018, the state legislature passed the Streamflow Restoration Act (SRA) to allow local governments to rely upon Ecology’s water rules; however, it required Whatcom County’s watershed Planning Unit and local governments to plan and propose projects that would offset future rural wells’ water use over the next 20 years. The plan would have to be submitted to Ecology before February 1, 2019 — otherwise Ecology would conduct rulemaking. The Planning Unit and governments failed to submit a plan in time and Ecology is now in rulemaking. 

The effort reinvigorated a much-needed conversation about our water supply challenges in Whatcom County. Many farmers lack sufficient legal water rights; streamflows in many creeks that support salmon are frequently too low; and our climate continues to change while thousands of people move to Whatcom County each year. Ecology is jumping to extreme, expensive measures in their proposed rule before even considering simpler solutions, like better conserving our water in the first place. Over the next 20 years, about 1 cubic foot per second — 210 million gallons — of water needs to be offset. This amount of water, which is equivalent to only about 4% of the water used in the City of Bellingham, can easily be offset by conserving water in existing rural homes and businesses. 

What you can do

Please ask Ecology online here to prioritize water conservation for residential and commercial water users, instead of projects that sacrifice water for farms in favor of rural development and expensive projects that will alter our environment. Comments are due May 10, 2019. This comment period is critical because Ecology will be taking your feedback to refine their rule for the official first draft coming out later this year. Here is the Supporting Document that we're commenting on. Questions? Contact Karlee Deatherage. karleed@re-sources.org or (425) 268-5245

Key points to urge the Department of Ecology to address in your comment:
  • Prioritize water conservation. The rule and supporting document provide little information about water conservation. Please provide information on how much water existing rural residents and businesses could save with rebates for efficient water fixtures (toilets, dishwashers, washing machines). Water conservation can meet  the 1 CFS requirement over the next 20 years.
  • Please tell us the cost per quantity of water saved for each project. In the supporting document, please include the cost per acre-foot of water offset each year ($/AFY). Knowing the cost per quantity of water offset will be important for decision-makers to judge which projects do the greatest good for the lowest cost to taxpayers.
  • Please don’t subsidize rural development with agriculture water projects. The SRA was written to address the impacts of new rural development using exempt wells. Any improvements in irrigation efficiencies and other agricultural water projects should provide water rights for farmers who lack sufficient legal water rights and improving streamflows. Please remove Projects 2 and 26 from consideration.
  • Please remove expensive, unpredictable projects requiring many permits. Projects 8, 24, and 28 won’t be needed if water conservation is prioritized and implemented over the next few years. Please remove those 3 projects.
  • Please remove the new section on exemptions. WAC 173-501-074 opens up interruptible rights for Projects 2, 8, 26, and 28. This won’t be needed if water conservation is implemented.
  • Address climate change impact on projects. Please add information on what effect climate change will have on all of the projects. 
  • Reduce water demand. Thank you for reducing withdrawal limits to 500 gallons per day (this is down from 3,000 gallons per day annual average).

Comments are due May 10, 2019. They can be submitted online or by mail.

Mail comments to:
Annie Sawabini
Department of Ecology
Water Resources Program
PO Box 47600
Olympia WA  98504-7600

Ecology’s website on Nooksack Watershed Rulemaking: ecology.wa.gov/Regulations-Permits/Laws-rules-rulemaking/Rulemaking/WAC-173-501