Propaganda Replaces Public Information:  An Analysis of the Lake Whatcom TDML Process

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The annual “state of the lake,” a meeting and public hearing regarding Lake Whatcom, is scheduled for March 26, 6 p.m. at Bellingham City Hall. This is an opportunity for the public, and the Bellingham City Council, Whatcom County Council and the Lake Whatcom Water and Sewer District commission to discuss the status of the lake and the joint strategy for the upcoming year.

Apparently, the jurisdictions have already decided one thing… that the planning process functions quite well without public input. I attend the “state of the lake” meeting each year, and this is the first time that a summary of status and a proposed plan have not been released for public review prior to the hearing. We have less than a week and half before the scheduled meeting. I would like time to review the proposal before my allotted three minutes of speech during the public hearing.

I guess we should be thankful to City Hall for notifying us at all. There is no information regarding the public hearing on the county website, the LWWSD website, or the Lake Whatcom Joint Management website (which reflects information on other meetings pertaining to the lake.)

But my gratitude has been diminished by the propaganda that we are being fed. It seems the only thing issued by the city these days is propaganda… by which I mean simplified information that reflects nothing but success, without a detailed background or discussion of problems, complexities, choices, trade-offs, competing priorities, controversy or community conflict. It is unrealistic and it is essentially dishonest. If the public is not provided with the actual truth, warts and all, it can not meaningfully participate in the public process. We need to hear the whole story, and increasingly, it is being withheld from us. One need only read the city press release for the “state of the lake” meeting to understand my concerns.

We all know the efforts to restore the lake’s water quality have been prolonged, controversial and largely unsuccessful. Lake Whatcom water quality continues to decrease almost every year, while algea blooms continue to grow and we increase the amount of carcinogenic processing necessary to clean our drinking water. There have been huge, and still unresolved, conflicts regarding the methods that should be used to achieve watershed restoration, such as downzoning, restrictions on lake use, or engineered stormwater solutions. There is conflict regarding who should pay for that restoration. A joint 2010-2014 Work Plan was nothing more than an unfunded wish-list of potential water improvement projects, which as drafted, had no potential to restore water quality.

Yet the administration’s message reflects a lovely success story. Under this revisionist version of Lake Whatcom history:

We have learned to effectively design and build stormwater facilities for our unique urban environment, to provide meaningful incentives that leverage private investments, and to deliver targeted messages to residents who can make the biggest impact. We have learned that success demands government action and public participation, so we work to inspire, cajole and provide incentives for good stewardship by watershed residents and visitors.

And the ability to achieve clean water quality standards is taken almost as a given, because, “our community’s work during the last five years proves that we can succeed…” One wonders why, if restoring the lake is this easy, it has taken so long.

Here is what we are not being told. Last year, a draft for Volume Two of the TMDL (total daily maximum load) Water Quality Improvement Plan was released by the Department of Ecology (DOE), and the final draft is expected to be released soon. For the first time, the city and county are obligated to provide funding estimates and proposed timelines under a deadline of October 2014. The city and county can no longer rely upon their ineffective five year work plans.

In other words, for the very first time, the city and the county must come up with a fairly detailed and serious response to its obligations under the TDML. I have discussed this situation in greater detail in a Whatcom Watch article available for review at

So where is this draft document and why has it not been released to the public prior to the public hearing? It is clear to me that a draft document exists. More importantly, why does the city notice fail to provide any real information about this situation? Oh, sure, it dances around the issue in a general and nonspecific manner, and states that:

This year’s Joint Councils and Commissions meeting marks a transition from envisioning a clean and protected lake, to making choices about how and when it will be achieved. Participating councilmembers and commissioners, with strong support from their respective administrations, will consider a joint resolution establishing strong and meaningful expectations for the next five years and beyond. In doing so, they will re-commit us to achieving our greatest community vision.

But a “joint resolution” hardly captures the reality of the situation, nor does it alert the public that extremely important decisions are being made regarding the foundations of a TMDL Water Quality Improvement Plan. There is no reference at all to the TMDL study or the DOE requirements. It appears to me that the city is trying to provide notice of this TMDL process, without really revealing that this is a TMDL process. I find this disturbing. As usual, the city wants to ensure that a plan is finalized and a “done deal” before the public has anything to say about it.

And there is something else equally disturbing about the city press release. The city appears to have made some policy decisions regarding how it will comply with TMDL obligations, bypassing an open public discussion. The mayor’s proposed plan appears to involve expensive, publicly funded engineered storm water facilities, and lots of incentives, in addition to public education and an expanded right to sell wholesale sewer services in the rural areas of the watershed.

Why has there been no public discussion of a major shift in policy away from land use regulations and enforcement and toward incentives? I want matters of public health and safety to be regulated, not subject to voluntary incentives. And why are we embracing offsite stormwater facilities when changes in state stormwater standards will soon require onsite LID infiltration techniques as the default standard? LID infiltration is more effective and promotes protection of open space, vegetation, habitat and wildlife.

And the city’s TMDL response fails to reflect updated science regarding watershed restoration. Clean water is the byproduct of a healthy lake. A water quality improvement plan that restores ecological integrity on a watershed scale has the greatest likelihood of success. When ecosystem processes are functioning, the land has enhanced resiliency and is better able to absorb the harmful impacts of human activity. But this approach to remediation requires respect for the limits of healthy ecosystems to absorb impacts, i.e, it recognizes that there are limits on development. And therein lies the problem. An ecological approach to water quality improvement would interfere with the city’s focus on short term profit almost as much as an informed and participating public.

I hope you will join me in speaking out against city and county failures to provide a copy of the proposed TMDL plan prior to the public hearing. I hope you will voice some of the same concerns that I have shared regarding the substance of the proposed plan, at least from what can be glimpsed in the press release. But most of all, I hope you will join me in turning a critical eye to the propaganda being released by the city and county, and demand full disclosure of relevant facts necessary for informed public participation.

About Wendy Harris

Citizen Journalist • Member since Mar 31, 2008

Comments by Readers

Marian Beddill

Mar 17, 2014

Wendy is absolutely right about every angle of Lake Whatcom pollution that I know about.

The pollution measurements show worsening status. But compliance with the State/Fed obligations for meeting the established TMDL (“Total Maximum Daily Load” of phosphorus) requires improving status - at least almost every year. Prime example - the City is now constructing a new pre-filter at the drinking-water treatment plant, because the amount of Phosphorus-fed algae blooms keeps on worsening.  And as closely as I watch the issue of the Lake, I did not know it was being planned until the construction was already being done.

In my earlier career, I was a researcher on water management systems - managing experiments to determine the best course of action to achieve the desired goal. Experiments such as these consist of doing a process in several different ways/quantities/methods, and measuring the results. Then select the best tested option to be used for the desired activity, in order to succeed. The City has not published (at least, not in a way that I have found it) the test results of the several ways to capture phosphorus before it is carried into the Lake by runoff.

My recent review of work done elsewhere informs that constructed “filter-boxes” achieve results of ONLY about 20% to 50% removal of P.  Failure, at great expense!  And when there is a big storm, ALL the polluted water bypasses the boxes, resulting in 0% (ZERO!) removal. How do they work? Phosphorus gets caught on a filter, which must be replaced frequently and the used ones hauled off to some “safe” disposal site.

“Rain-Gardens” achieve results of about 80% removal of P (at least, when properly installed and upkeep well done.)  Success, at substantially reduced expense!  How do they work? Phosphorus goes into the soil, and plants (usually bushes) capture the P with their roots, thus growing bigger. The City has done some of these—why not do all? 

Dear Public:
Please help on this question, by asking the three governments (City of Bham, County, and LW Water&Sewer; District) to provide the public with the “test program results reports” (generic report-name - I’ve not seen a real one, either) of Phosphorus-removal effectiveness tests, which quantify costs and results! (Think about asking your doctor if he would prescribe an untested medicine for you?)

And please report back what response you get from the governments.


Marian Beddill

Mar 17, 2014

I sent an email to City and County.  Received a reply from County Exec, directing Staff to review and reply.

At least that’s something.


Stan Snapp

Mar 18, 2014

Wendy and Marian certainly have this right. I worked for six years on city council trying to get an actual Restoration Plan from staff and the administration for council approval. Nada. We did manage,over the current Mayor’s objection, to implement a Surcharge to purchase more property for long term protection and to improve storm water processing. This is year three of that Surcharge and property has been protected but not a single infiltration project has come from that increased resource. The HIP (homeowner improvement program) can help but it’s mostly a one person effort in a department of 250 employees. Too little and maybe too late. I do know that many council members have tried to provide leadership in this program but staff in the city work for the Mayor. Her platitudes do little to make the lake cleaner and DOE is all but useless as they extend time frames for plans and even further out; actual actions. Thanks Wendy for your tireless efforts; I’m through with attending these meetings.


Marian Beddill

Mar 18, 2014

Thank you for this update, Stan;

Today, I have also received messages from a City staffer, including some technical reports from previous work which appear to be relevant.
They are rather technical, and address other factors (like $) besides P-removal effectiveness. I am digging into these items.

No surprise, much of the work I have seen has a large element of costs, as criteria for applying judgement to a proposed process.
But we (and they) must, I believe, look at costs from two sides:
(a) What will it cost to DO something (like build P-removal facilities of the several types.)
(b) What will it cost to NOT DO something (like not remove P, then be forced by the State/Fed, to do big stuff at very high costs in order to meet TMDL.)

I hope that the City has—or will prepare—an alternatives-study for effectiveness options - i.e.: How much P will each method remove from runoff, thus prevent from entering the Reservoir? 

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