Friday, February 20, 2009

NMFS wants to set WRIA 17 reserves to ZERO nearly everywhere

Sunday, February 01, 2009

NMFS wants to set WRIA 17 reserves to ZERO nearly everywhere

We now have a preliminary draft rule for WRIA 17's instream flows and other water management considerations. While far from perfect, we have something to work with, and we are developing new ways of working that will actually be capable of providing additional water for farms, fish, and people.

(Before we go any further, we need to understand that "farms, fish, and people" is phrased in alphabetical order. So long as these three primary user group classifications are discussed on an even keel, we can have a productive conversation. As soon as one of the groups is elevated above the other two, though, the conversation has a rather nasty tendency to dissolve into a confrontational mess.)

So . . . into the discussion steps the National Marine Fisheries Service (NMFS) Habitat Conservation Division with their "informal early comments" on the Department of Ecology's on the preliminary draft of Chapter 173-517 WAC, Water Resources Management Program, Quilcene-Snow Water Resources Inventory Area (WRIA 17), otherwise known as the WRIA 17 instream flow rule. (The preliminary draft is open for public comment until February 13, 2009, so please go to this page, download a copy for yourself, and make as many constructive comments as you can, so that you can help Ecology make edits that will be helpful to those of us who live in WRIA 17.)

What does NMFS ask Ecology to do? Hold onto your seat . . .

In an email sent to the Department of Ecology, and obtained by the Peninsula Daily News and others at a public meeting we see:

"NMFS has identified several of the streams described in the Preliminary Draft Rule as important for conservation of summer-chum (listed as Threatened under the Endangered Species Act). Specifically, Big Quilcene, Little Quilcene, Chimacum, Salmon, and Snow creeks are key for recovery of the summer-chum, and are each flow limited. Therefore, NMFS recommends the Preliminary Draft Rule be revised to Not allow any additional water withdrawals from these streams."

. . .

"NMFS recommends that proposals for additional, capped allocations of water from the Big Quilcene (15 cfs) and Chimacum (3 cfs) be revised to 0. In addition, NMFS recommends that additional water proposed for withdrawal, termed "reserves," be revised to 0 for Chimacum, Little Quilcene, Salmon, and Snow creeks. We note that Big Quilcene has a larger watershed and different hydrology from the other streams and may be able to accommodate a small amount additional water withdrawal, but much less than the proposed reserve of 200,400 gpd or 0.31 cfs. A reserve amount close to 20,000 gpd (0.03 cfs) would be an acceptable withdrawal for summer-chum salmon conservation in the Big Quilcene."

So, there you have it . . . NMFS has most certainly elevated the fish primary user group way, way above the farms and people groups. (We understand that, while NMFS generally responds to Ecology's requests for review and comment, this level of detail is unprecedented.) This makes discussion toward an improved way of managing our local water resources a more difficult task, even though we are going to need to have that discussion.

What we are trying to accomplish is the development of a local water resource management program that will make more water available for all uses. The folks in the Walla Walla Basin are having remarkable success with this approach, to the level of being able to provide water to streams that used to go dry every year. Salmon are now returning to those streams. With broad local support from the full range of water using interests, we can do the same here, and have already been asked to give it a try. We are not going to be able to go far enough down that road if NMFS digs in its heels and insists on their recommendation becoming law in WRIA 17.

Have you noticed that things have changed a tad since last summer, when the global, national, and regional economy was still ticking along more or less as usual? Would you say that the time for "business as usual" is well and truly over? With our national leaders and a growing number of leading economists accepting that we are in a recession that isn't going to be over any time soon . . . and that may, indeed, come to resemble a replay of the 1930s, we really need to take a reality check and plan for and prepare ourselves and our local region for some pretty tough times. If it doesn't happen, at least we will be further down the road toward meeting the demand for locally grown produce. If it does, then we will be better able to feed ourselves and our neighbors.

How did people around here make it through the Great Depression? Well, several long-time residents say there were few, if any lawns in Port Townsend, because everyone had vegetable gardens. The following decade those gardens gained the moniker of "Victory Gardens". Many families moved out of cities and towns and onto farms. Those who did managed to get through the hard times better than many of those who didn't have a farm to go to.

We need to increase agricultural production on existing farms and other suitable parcels. We should also make greater use of greenhouses. The use of higher efficiency watering practices will need to be a given. While we're at it, we need to make sure there's additional water in our streams when it's needed, because until we satisfy that basic condition, we're not going to be able to have additional water for growing food.

We can accomplish this and more, providing we have reasonable access to our water resources. With water banking, the ability to actually put additional water into our streams when they need it, and a locally-driven water management program, we can do it. If NMFS persists in insisting that the water in WRIA 17 is going to be a "no touch" resource in terms of supporting those needs, then it's going to be a much harder task than what we are already looking at.

What we need now is for NMFS to take a step back, take a deep breath, and see what we can do. Better yet, NMFS could even help us accomplish the dream. How about we ask that they not only give us a chance, but also help by becoming a part of the solution, rather than maintain their current position as a barrier to success?

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