February 23, 2017
Mr. Ben Rau, Water Quality Program
Washington State Department of Ecology
PO Box 47600
Olympia, WA. 98504-7600
Dear Mr. Rau:
The Interagency Team (Team) appreciates the opportunity to provide input on Ecology’s Draft Process
Design – Clean Water Guidance for Agricultural Activities (Draft Process). The Team generally supports
Ecology’s goal of producing voluntary clean water guidance for agriculture (Guidance Document). The
team also supports the type of background information proposed for inclusion: i.e., the water quality
parameters the practices address; applicability and design considerations; implementation
considerations and costs for operation and maintenance requirements; and effectiveness. This
background will provide practical information and enable users to understand expected pollutant
reductions from the practices. It should help Guidance Document users plan, design, implement and
maintain the most effective combination of practices that are reasonably expected to support
compliance with water quality standards and provide assurance to municipalities that the impact of non-
point source pollution is being reduced.
The Team supports the proposed structure for an advisory group being made up of an implementation
evaluation workgroup and an effectiveness evaluation workgroup. We agree with the concept of the
workgroups working separately, but in parallel, with opportunities for joint discussion during meetings
of the full advisory group.
The Team supports the recruitment of advisory group members that will comprise a balanced mix of
participants and represent diverse perspectives. We encourage Ecology to ensure the advisory group
include a wide range of agricultural producers to account for different perspectives, scales of operation,
economic viability, and geographic variability. To the extent possible, representatives of “producers and
producer groups” should be farm operators and rural landowners, rather than trade associations, which
may have less practical experience.
Ecology is correct to recognize that “It will be important to provide implementation support to
landowners to encourage the adoption of voluntary clean water practices, particularly for practices that
require significant investment, on-going maintenance, and/or take land out of agricultural production.”
Additional public investment is needed to incentivize the implementation of effective practices that
yield water quality benefits in watersheds where nonpoint sources contribute to water quality
impairment.
The Draft Process describes the goal of the Effectiveness Evaluation Workgroup to determine what
pollution control or reduction can be expected from various clean water practices. The Team agrees
with Ecology’s plan to use quantitative estimates of practice effectiveness, where possible; with
qualitative information used only when necessary. The Team strongly encourages Ecology to utilize
credible data and science (as described in paragraphs c-e of the Effectiveness Evaluation Workgroup
section). Further, the Team supports an independent peer review of the Effectiveness Evaluation
Workgroup’s final product. We recommend the review be completed by peers representing diverse
Mr. Ben Rau
February 23, 2017
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perspectives, including representatives of producers. We believe this independent peer review process
will increase transparency and overall confidence in the process.
When the guidance document is finalized and published, the effectiveness information should be
presented in a format that is useful at the farm/site level as well as the basin or watershed scale. The
Guidance Document should:
1) help landowners compare the costs and benefits of different practices, alone or in combination,
2) guide implementation actions necessary to meet water quality standards, and
3) help municipalities and others provide technical assistance to producers.
Given the spectrum of site conditions that can impact pollutant concentrations and loading to receiving
waters, the effectiveness evaluation workgroup should consider how best to provide reliable estimates
of effectiveness for practices that treat or reduce the loading of pollutants. The Guidance Document
may need to include additional information on the operational factors and/or site conditions that could
alter the effectiveness of various practices and what source control, pre-treatment, and/or practice
combinations could improve overall effectiveness and attainment of water quality standards. Ecology
should explore and include links to peer-reviewed internet-based conservation practice tools or
organizations that could make the process more user friendly and productive.
The Team appreciates Ecology’s plan to make progress on the first set of clean water practices by July
31, 2017; but has some concerns with the implementation of “… a rolling process where work on sets of
practices are finalized and added to the guidance document on an on-going basis.” The Team notes that
the Draft Plan is somewhat vague about how the public will be engaged and be allowed to review draft
versions of the guidance document before it is finalized. It is suggested that Ecology follow a sequential
process: “Advisory Committee/Ecology Develops Draft > Release Public Draft > 30+ day Public Comment
Period > Final Document Published” at regular intervals to support participation.
The Team appreciates Ecology’s commitment to develop Voluntary Clean Water Guidance for
Agriculture using an inclusive, balanced, data-driven process. Please contact Jeff Killelea at 360-867-
2073 or [email protected] if you have any questions about our comments.
Regards,
The Interagency Team: City of Bellevue, Clark County, King County, Kitsap County, Pierce County,
Snohomish County, Thurston County, and the Washington State Department of Transportation
cc:
Melissa Gildersleeve, Watershed Section Manager (ECY)