Addressing a statement by Whatcom County Council Member Brenner at 4/18/17 Council Meeting regarding exempt well report / Letter to Council Member Barbara Brenner, Dena Jensen

consumptive water use chart exempt wells doe

April 28, 2017  Dena Jensen

Below is a letter I sent to Whatcom County Council Member Barbara Brenner regarding a statement she made at the April 18, 2017 Whatcom County Council Meeting related to a Department of Ecology report on exempt wells.  The Council was voting that night on interim amendments to the Whatcom County Comprehensive plan pertaining to the Hirst decision.

Sent: Friday, April 21, 2017 4:33 PM
To: Barbara Brenner
Cc: Carl Weimer; Ken Mann; Rud Browne; Satpal Sidhu; Todd Donovan; Barry Buchanan; Council
Subject: About a statement you made on the DOE study on

Dear Council Member Brenner:

I am writing regarding a statement you made at the April 18, 2017 regular County Council meeting toward the end of the discussion, before the Council’s vote on the “Ordinance adopting interim amendments to the Whatcom County Comprehensive Plan and the Whatcom County Code Title 15, Buildings and Construction, Title 20 Zoning, Title 21 Land Division Regulations, and Title 24 Health Code, relating to water resources.”

Someone may have brought this to your attention already, but if not, I wanted to be sure you had this information.

First I made a casual transcription of your statement and provide it here so that you can see what statement I am addressing. It should be reasonably accurate to my best ability (without any pausing words included):

“I just want to make a correction.  Someone had said that what we’re talking about with exempt well use being .7 % is based on usage, not on what’s allowed, and that is not correct because the Department of Ecology didn’t go around and knock on everybody’s door and ask them how much they’re using if they have and exempt well. They calculated it based on allowance, not on what people are or are not using. And that’s important because that says it’s .7% with the amount that is allowed presently.  So even though someone says, ‘well, it’s so much,’ it’s very little. ”

I believe, in fact, the information from Department of Ecology’s February 2015, “Permit-Exempt Domestic Well Use in Washington State,” (Publication no. 15-11-006) is based on consumptive water use estimates, not on what the allowance is for permit-exempt domestic wells. I hope I am correct that this is the study you were referencing.  It does provide the .7% figure of exempt well water usage for Whatcom County.

Here are a couple paragraphs and Table 3 from the report that seem to indicate this. I am not a scientist by a long shot, but I feel like this material makes the basis of the report on consumptive water use estimates pretty clear.  The table is labeled “Washington growing-season estimated consumptive use rates by county.”

“U.S. Geological Survey Total Water Use Estimates 

The consumptive water use estimates produced during this Ecology study are based on total water use estimates contained in the 2009 USGS publication, “Estimated Water Use in Washington, 2005” by R. C. Lane4. This report presents state and county estimates of self-supplied and public domestic water use, as well as irrigation, livestock, aquaculture, industrial, and mining water use in Washington in 2005. In 2014, the USGS indicated that the population values (used in public- and self-supplied estimates) published in the 2009 report were incorrect and republished a new data table in a web-only format. Those new numbers have been incorporated into our analysis.

The 2009 USGS study derived self-supplied and public-supplied domestic water use numbers from several sources. For public-supplied water use, the USGS obtained system-specific withdrawal and use information from representative Group A systems, which they used to calculate per-capita rates for each system. Using those results combined with population and data for the non-reporting systems, they estimated the total population served by public-supplied water for each county. Self-supplied domestic use was then estimated using the difference between estimated populations served by Group A systems and U.S. Census Bureau population estimates. A weakness with this approach is that it relies on data reported by Group A water systems to WDOH, which may or may not be accurate.

The 2009 USGS investigation estimated irrigation of crops and golf courses based on representative water use data extrapolated to larger areas based on acreage. The report’s industrial use data are the most suspect due to very limited source information; however, this does not affect the conclusions significantly because industrial use tends to be small compared to other uses.

“Total versus Consumptive Water Use 

Total water use includes both consumptive water use (water lost to evaporation and transpiration), and unconsumed water (water that drains through the soil to recharge groundwater). When evaluating the relationship between total use and consumptive use, one key publication relied upon was the report, “Consumptive Water-Use Coefficients for the Great Lakes Basin and Climatically Similar Areas” by K. H. Shaffer and D. L. Runkle (USGS SIR 2007–5197, 2007). For the purposes of that study, consumptive water use was defined as:

“…water that is evaporated, transpired, incorporated into products or crops, consumed by humans or livestock, or otherwise removed from an immediate water environment (water body, surface- or ground-water source, basin). Water-resource planners and managers use consumptive water use to understand the effect of human use of water on the hydrologic system.”

Two common methods of computing consumptive use are water-balance equations and consumptive-use coefficients. The Shaffer and Runkle study relied upon the latter. The report contains statistical analyses of coefficients generated by many other studies for the Great Lakes Basin (the focus of that study) and areas throughout the world with a similar climate (Figure 1). For this evaluation Ecology used the median values from this Shaffer and Runkle study. In keeping with the Great Lakes Basin medians, for irrigation and mining we used the round values of 90 percent and 10 percent, respectively. The selection of 5 percent consumptive use from aquaculture was simply a small number chosen to represent a small amount of consumptive loss from aquaculture operations.”

[Table 3, labeled “Washington growing-season estimated consumptive use rates by county,” shown at the top of this post was inserted here in the email]

If hope if you, or any Council Members who I copied on this, find I am in error, you will let me know.


Dena Jensen

Birch Bay

This letter was sent to:

And copied to:


4 thoughts on “Addressing a statement by Whatcom County Council Member Brenner at 4/18/17 Council Meeting regarding exempt well report / Letter to Council Member Barbara Brenner, Dena Jensen

  1. Okay, time for me to weigh in on the bad science, bad statistics, and bad logic bandied about in your article.

    BAD SCIENCE: Assuming coefficients developed for “the Great Lakes Basin and other areas throughout the world with a similar climate” does not apply to a maritime climate, like here in Whatcom County. More investigation into the Shaffer and Runkle study is an absolute must before just accepting their methodology. I downloaded a copy of the Shaffer and Runkle study in PDF format and I will take a look at it. It is 200 pages but I should be able to get the gist of it by skimming. It is NOT okay to just accept it because some “scientist” says it is the sine qua non of water research. Its methodology is suspect right from the git go.

    BAD STATISTICS: First of all, Disraeli was reported by Mark Twain to have said, “There are lies, damn lies, and statistics.” Using a 2009 study that is actually about 2005 and then plugging in new numbers is stinky cheese. Also there is waaaayyyy too much extrapolation going on here – from Group A systems to other systems and then having the gall to still use them after admitting that Group A data “may not be accurate.” Really, all the statistics are suspect. Also notice that, even though they “supposedly” have Group A measurements, they STILL use a default percentage. “In keeping with the Great Lakes Basin medians, for irrigation and mining we used the round values of 90 percent and 10 percent, respectively.” Then they go on to say, “The selection of 5 percent consumptive use from aquaculture was simply a small number chosen to represent a small amount of consumptive loss from aquaculture operations.”

    BAD LOGIC: If we take the numbers as valid (which is a big IF) then we can easily see that in Whatcom County during the four month period, permit exempt wells account for less than 1% of water use (.6% or .7%), while irrigation accounts for 82.9%. So why in the hell are permit exempt wells even an issue? In fact, what do you think I have been on about since 2010? Permit exempt wells are NOT the cause of salmon dieoff or the lack of instream flows or the inability of people to get clean water or the runoff that pollutes the waterways or any of the other reasons for action on water usage in Whatcom County.

    Finally, think of this. The total in the Whatcom County line in Table 3 is 95.2% of water usage during the 4 month period. That leaves 4.8% unaccounted for – 7-8 TIMES as much as the permit exempt wells! Fer chrissakes, this whole issue focus on permit exempt wells is riddled with bad science, bad statistics, and bad logic.


  2. Okay, I started looking at the Shaffer and Runkle report and it is specific to the Great Lakes area. It does not apply to the Pacific Northwest. If you look at the map of the continental US on page 6, you will see that the Great Lakes coefficients would only be applicable to Upper Mississippi, Mid-Atlantic, Tennessee, Ohio, and New England areas – the “climatically similar areas” mentioned in the title . Also look at what constitutes the Pacific Northwest. It ranges from the edge of the Great Basin to intermountain west to desert to rainforest to alpine environments to coastal areas. It is a catch-all category that has no grain. It is not just coarse-grained – it has no grain at all! Misusing the Shaffer and Runkle report is just abuse of science.


  3. I agree, we need more and better studies. Let’s fund and do them. Meanwhile, from what I can tell this is something that seems to have gotten the ball, however-wobbly, rolling with our local governments on water quality and water rights issues. It seems crazy that us people can’t make things work before there’s a court decision, but in this case, we certainly haven’t. We’ll see if we can do it post-decision.


    • Meanwhile, the proponents of the Hirst Decision want to put meters on everybody. This means new costly infrastructure on my farm, even though we have senior water rights that stretch back before 1910, when our house was built. Since I have been advocating for restricting water use by industrial agriculture in Whatcom County since 2004 when we got here, what happens is that I get penalized even though the culprits are the dairy farmers. This is beyond ironic into absurdity. All the people who support the Hirst Decision have not thought it through.


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