September 25, 2008
 
Mr. David Dicks
Executive Director
Puget Sound Partnership 
P.O. Box 40900
Olympia, Washington 98504-0900
 
Dear Mr. Dicks:
 
As your staff works to finalize a public review draft of the Partnership’s proposed Action Agenda for Puget Sound, we ask that you take bold action – as Governor Gregoire has directed – to effect a dramatic improvement in the health of the Sound. As longstanding members of Washington State’s scientific community, we have witnessed the failure of past initiatives that promised much but did little to reverse the downward trend in environmental quality of our cherished estuary. We sincerely hope that the result of the current initiative will accomplish this goal, and it is in that spirit that we offer these comments.
 
As a group, we previously made our views known in a letter (October 26, 2006) to the Partnership’s predecessor Advisory Commission.  Individual members of our group have also worked directly with the Partnership staff and committees to identify and address key concerns. In this letter, as in our previous one, our comments are focused on stormwater—certainly not the only important issue before the Partnership, but one that is central to success, and one on which we collectively have considerable expertise. We stand ready to work with you to clarify and elaborate the thinking summarized in this letter.
 
The current abuse of land and water resources must be drastically reduced if we hope to ensure a healthy Puget Sound. This requires us to reduce impervious surface that impairs the hydrology of streams, restrict new clearing and development that would harm remaining undisturbed habitats, restore and conserve healthy living systems, and, to the extent possible, eliminate discharge of pollutants. This requires significant changes in policies, law, and behavior that would continue long after our generation is gone.
 
Undoing the harm of ongoing land use practices and preventing further degradation from new development requires a fundamental commitment to implementing low-impact development practices throughout the region. This involves not only structural solutions (e.g., pervious pavement, rain gardens, green roofs) but also operational and design choices (e.g., water harvesting, preservation of soils and vegetation).  Although not every method of low-impact development is appropriate in every circumstance, taken as a whole, LID practices are both more effective and much preferred over existing methods used to treat stormwater. Some may argue that these practices are untested, too expensive, or ill-suited to urban areas and the till soils of our region, but the record emphatically suggests otherwise; the success of LID techniques and practices is well documented, both locally and around the world. If other agencies, institutions, organizations or individuals assert otherwise, we hope the Partnership will provide a forum for interested parties to examine the factual record and debate the merits of opposing views.
 
Stopping the degradation associated with new development is necessary to reverse past trends and successfully restore the Sound, but it is not enough.  We must also rehabilitate existing disturbed areas. Incentives should be provided to induce residents and businesses to voluntarily restore the hydrologic integrity of their land. However, incentives and ad hoc approaches to restoration are unlikely to prove sufficient; the severity of the problem demands the investment of resources at an unprecedented scale.
 
Clearly, recovery of the Puget Sound ecosystem requires both ending ongoing losses of habitat and aquatic life from new development and rehabilitating areas that have already been developed. We remind the Partnership that this recovery must be measured not by the amount of money spent, laws promulgated, BMPs installed, numerical water-quality criteria focusing on chemical pollutants, or administrative milestones, but by the presence of living systems that are the surest indicator of our success at attaining the ecological health goals articulated in Partnership documents. The public will accept nothing less than that the ecological health goals have been met.  
 
Based on consideration of the foregoing stormwater management issues, we recommend that several concrete actions be accorded special status in the Action Agenda.  All of these actions have been articulated by multiple groups on numerous occasions over the past several years, but nonetheless bear repeating:

• Protect existing high-quality habitat, the “last best places” in the Puget Sound watershed; 

• Replant forests and restore wetlands and riparian environments throughout the Puget Sound watershed;
• Control inputs of toxic consumer products at the local and/or state level;
• Adopt LID as a mandatory element of state and local stormwater codes for new development;
• Begin progressive retrofitting of developed areas (i.e., existing urban and suburban areas) to reduce their negative effects on Puget Sound and associated water bodies;
• Integrate land-use codes and land-use decisions into an overall strategy for protection of Puget Sound; and
• Implement a program of adaptive management to ensure that clearly articulated assumptions about the response of the ecosystem to our management efforts can be tested, and our efforts subsequently modified for greatest effectiveness.
  

These seven actions are grounded in the broad understanding that degradation of the Puget Sound ecosystem is fundamentally an expression of land-use practices and the policies and laws that enable them. 
 
The Puget Sound Partnership faces enormous challenges.  In the interest of bequeathing a healthy Puget Sound ecosystem to future generations, we call upon the scientific community and, specifically, offer our own services to help the Partnership meet those challenges. We feel strongly that recent advances in scientific understanding and practical experience can be effectively applied to address the problems confronting us.  Above all, we do not want to bear collective witness to another failed attempt to restore and protect Puget Sound. If we can succeed in reversing current trends, we will provide a much-needed example to the world of how
a highly developed society can find a way to prosper by protecting the environment upon which it depends.  
 
Sincerely,
 
Douglas Beyerlein, Professional Hydrologist and Professional Engineer
Susan Bolton, Ph.D., Professional Engineer
Derek B. Booth, Ph.D., Professional Engineer and Professional Geologist
Thomas W. Holz, Professional Engineer
Thomas Hooper, Fisheries Biologist
Richard R. Horner, Ph.D., Environmental Engineering Research (TO BE CONFIRMED)
James R. Karr, Ph.D., Ecologist
DeeAnn Kirkpatrick, Fisheries Biologist
John Lombard, Planner and Environmental Policy Analyst
Christopher W. May, Ph.D.
Gary Minton, Ph.D., Professional Engineer
David R. Montgomery, Ph.D., Professor of Geomorphology
Cleve Steward, Fisheries Biologist