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Kenai River DEC comment period on impaired listing

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  • Kenai River DEC comment period on impaired listing

    It is time for sport, commercial, and personal use fisherman to pull together and support the listing of the Kenai River as impaired. DEC has listed the river and the document is out for public comment. They need comments supporting this lisitng and I urge everyone to write a short email supporting them in this action. While it is hard to believe there are those who use the river who do not want it listed as impaired, even with 6 years of data on fuel levels.
    Following is the information I received on the public comment process.
    The 2006 Proposed Integrated Report is currently out to public notice. The notice was published in the Anchorage Daily News, News Miner and Juneau Empire. DEC has a web page with the Proposed Report, supporting documents and public notice information at:

    A straightforward fact sheet on the whole document is available at this link:

    Written comments to:
    DEADLINE for submissions is 5 PM Alaska Time, December 1, 2006.
    Send written comments to:
    Drew Grant
    PO Box 11180
    410 Willoughby Ave Ste. 303
    Juneau , AK 99801
    Phone: 907-465-5304
    Fax: 907-465-5274


  • #2
    The cavalry to the rescue. . .

    Gosh, Nerka, don't be too alarmed. True, things look bleak, but I'll bet the in-river commercial fishermen and their advocates will get things back on the right track. I kind of look for KRSA, KRPGA, and the unaligned guides to now advocate for smaller motors, lighter loads, more drift boat days, and fewer trips. Want to bet?

    Heck, KRSA's motto used to be, maybe still is, "Think habitat before it's too late." It's not too late, is it?


    • #3
      The beginning of the end?

      In all seriousness, I think what we're seeing is the beginning of the end of the unbridled expansion of the Kenai River's sportfishery, especially of the river's commercial sportfishery.

      The satire in my post above was intended to illustrate the total inability of the Kenai's commercial sportfishery and its advocates to restrict themselves. Nor should anyone expect them to. Nerka should not find it hard to believe there are some who don't want the Kenai listed as impaired because, in the majority of cases, economics determine ethics. Consider the antebellum South, which committed economic and social suicide trying to preserve the economics of chattel slavery.

      I think we're seeing the beginning of serious curtailment of the Kenai's sportfishery for a number of reasons. First, while the Feds may not be holding cards quite yet, they're in the room, looking to getting in the game. The EPA and the Clean Water Act are and will be powerful players. Society in general has less and less tolerance for desecration of the environment in the pursuit of special interests.

      Second, the commercial sportfishery, already held in derision by many area residents, will have to increasingly compete with the interests of a burgeoning resident population. Outfits like Lowe's and WalMart aren't coming to town because they think the population is decreasing.

      Third, as world fisheries face collapse (see the lead story in today's ADN), Alaska's wild fisheries will assume greater and greater importance in the world's efforts to feed itself.

      Much more could be said, but that's how I see it. Were I a young man who depended on the Kenai's sportfishery for my income, I'd be thinking ahead, thinking of guiding bird watchers, hikers, wildlife viewers, and more.


      • #4
        Very well put Marcus,

        While I do not rely on the Kenai for my bread and butter I as a commercial sport fish business am watching closely what happens.

        The last time the Kenai took radical changes it effected my home waters in its wake . We, state wide need to be on short alert for our actions and the results.



        • #5
          Siren song . . .

          I think someone's trying to seduce us into believing we can build a growth industry on a finite resource.


          • #6
            How about asking them to apply science?

            "As much as 600 gallons of gasoline a day are dumped into the Kenai River during the month of July"

            Does that sound like a scientific statement?

            Exactly what does that mean, and how was that number arrived at.

            Does that mean that by somebody's estimate 600 gallons were "dumped" (isn't that a very professional word for our state DEC to be using) once? twice? daily?

            Was this arrived at based on a mish mosh of data taken from multiple unrelated and uncoordinated sampling efforts?

            Before this DRASTIC step is undertaken some pretty serious science had better take place, and that means the sampling data needs to be really looked at.

            When and where those samples are taken is CRITICAL. For example, fuel if samples are taken on the surface and then extrapolated to the entire water body that will give an inaccurate (HIGH) number........if samples are only taken sub will give an inaccurate (LOW) number

            sampling just downstream of large concentrations of boats or too far below where large numbers of boats will be operating will also give fairly useless data

            the bottom line is a well thought out specific STUDY needs to be done before something drastic like this is done

            Finally I'm NOT a commercial sports fisherman but I wouldn't get too smug thinking they're the ones who might suffer consequences because of this.

            How many locals are going to be forced off the river if 4 stroke motors are mandated and perhaps even some regulation that boats MUST have at LEAST 3 or 4 people on board ???? (thus maximizing the recreation to pollution ratio)


            • #7
              Doing our homework. . .

              AKCheese: Read through the 50 horsepower thread on this forum, contact Kenai Watershed Forum, and Alaska Department of Environmental Conservation for an understanding of the thoroughly scientific nature of the pollution studies that have led to the Kenai's threatened, impaired status.

              Second, the 4-stroke/2-stroke question is not so easy to resolve nor is it the end all, be all solution to the Kenai's problems. Use, private and commercial, continues to increase, some 2-strokes are—as I hear it—less polluting than some 4-strokes, what standards are we shooting for, and more. What's the answer—emission testing for boat motors?

              Finally, while mandates resulting in decreased use of the Kenai would cause some discomfort, both private and commercially, we'd survive. Look at big game hunting, for instance. Some would welcome such a change. There are more than a few who now view the Kenai River sportfishery as a gong show, a dog-and-pony circus. Not saying I agree or disagree.


              • #8
                If we insist on addressing this questionable "problem"

                First off this 10 parts per billion limit is something that does not exist in any other state in the union. It is a totally arbitrary figure that ONLY exists in Alaska. The EPA will not get involved because THEY think there's a real problem, the EPA will get involved because according to ALASKAN regulations there is a problem.

                This limit was created in response to fears that oil pipelines would create ongoing long term pollution problems in our water. So basically a limit which was created to address "pollution" which would occur 24 hours a day 365 days a year is being applied to a situation which occurs for a handful of days during the month of July and at no other time during the year.

                Applying this "local" standard literally ........which EPA could well decide to do......would make it illegal to operate an outboard motor on any water in this state..........because any outboard motor will cause an exceedance of this standard

                be that as it may.......

                "some 2-strokes are—as I hear it—less polluting than some 4-strokes"

                Marcus I don't know where you heard that but whoever said it is just plain wrong. Those are the kind of irresponsible statements that are all too casually thrown around in what SHOULD be a discussion based on facts and science

                The first step to fixing "the problem" is get the 2 stroke motors off the river....

                An emmisions testing procedure might be the next step

                The next step IS to reduce the number of boats on the water........

                Put a $100 fee to launch a boat in effect on the Kenai during the month of July and the problem will disappear

                If $100 won't work then make it $200

                heck I'd love to see them make it $500........

                That money could be used to protect the banks and enhance habitat upstream

                of course then you will have exactly what you have with big game hunting..........

                people who are fortunate enough to live in close proximity to the resource (i.e. ON the river) or people with a lot of money........will be able to fish

                As I said..........I really don't have a horse in this race.........just be aware of exactly where this is heading before you encourage people to zealously jump on a bandwagon which could lead to a lot of things people aren't anticipating


                • #9
                  AkCheese - response

                  I think to debate the science at this time is a waste of time. In 1991 FRED of ADF&F first noticed the issue of fuel in the river. They also sampled resident fish and found responses to stress but did not have the data to figure out whether it was fuel related or not.

                  Over the past 6 years DEC and outside groups have conducted a well planned and executed study of this issue. The data are published and sampling and analysis does meet the professional standards you want AkCheese - people should read the reports and talk to Rober Ruffner at the Watershed Forum.

                  Relative to the 600 gallons a day comment it was an effort to make this real for the general public. Talking in parts per billion does not relate for most people. However, you can look at the individual sampling events to see when standards are exceeded. It makes no difference if it is all at one time or over time - the standard is exceeded. However, from what I can see in the data is that fuel is mixed in the water column and present over long periods of the day (when boats are present).

                  Finally, relative to the standard DEC Director of Waters Lynn Kent stated that they review the standard every three years and in the last review kept it at 10 ppb. However, she stated that data did exist that suggested it should be lower - maybe even to 1 ppb. Therefore, there are no data to raise the standard and there are data suggesting it should be lower.

                  In summary, if you want to go the way of other States fine with me but look at the resources they have - I think that answers the question for me on which direction to go. Precautionary is better than risk taking at this point in time.

                  This is a significant event in the history of the Kenai. A clean river 30 years ago is now polluted - lets forget spin words like impaired - it is polluted in July due to human activity.


                  • #10
                    To be accurate and factual

                    The Kenai River and any water body on which an outboard motor operates is polluted in exceedence of the Alaska Water Quality Standards.

                    There is no provision for a mixing zone for the discharge from an outboard motor, and mixing zones are prohibited in salmon spawning streams in any event. The fact that this 10 ppb limit is exceeded at the prop is a violation and this occurs NOT just for a few days in July but any time an outboard motor is operating.

                    Are you ready to ban the use of outboard motors in this state?

                    Oregon which is an extremely environmentally sensitive state has a limit of 100 ppb..........that is the next lowest limit after Alaska.

                    The next thing we'll hear is the wailing and gnashing of teeth over not wanting our salmon runs to go the way of Washington, Oregon and California

                    This sounds great, but the facts are that those runs have not dissapaited due to pollution, for the most part they were negatively impacted due to dams and loss of habitat.

                    There is no evidence to show that this level for a short period of time is having ANY negative impact on our fish runs.

                    As far as there being "evidence to suggest" that it should be lower, there is evidence to suggest a lot of things. That's another one of those phrases that is bandied about when people do not have enough evidence to actually PROVE something.

                    It doesn't really matter. The river is going to be listed as impaired........PERIOD. Then watch the politcal posturing and self interest begin as to how it is going to be "unimpaired".

                    I like my idea of banning 2 stroke motors and charging hefty boat launch fees in July to limit use. This money can then be used for bank restoration and habitat enhancement.

                    The danger I see is.......

                    There's an old saying about the camel getting it's nose into the tent........and once EPA is invited to enforce our regulations for us the truth of the matter is every outboard motor ever created by man pollutes any body of water it operates in in violation of Alaska Water Quality Standards.

                    A lot of people will say that's fine (including me ..... I don't own an outboard motor) we'll start getting into the question of lead sinkers.......then the whole issue of "torture and release" fishing..........

                    once you throw fact and reason out the does really get to be quite amusing *LOL*


                    • #11
                      No glib answers. . .

                      Originally posted by AKCheese View Post
                      once you throw fact and reason out the does really get to be quite amusing *LOL*
                      Would that it were that easy, but one man's amusement can be another man's tragedy.

                      Have you shared your thoughts with the Kenai River Special Management Area board (I think they have a meeting coming up on the 9th), Department of Environmental Conservation, Kenai Watershed Forum, and Department of Natural Resources?

                      In the end, EPA will only come in if we don't follow the rules, and I think that's already been tried.


                      • #12
                        It might be to late but...

                        10ppb is not much. Now I understand that humans and fish may have different tolerance levels but it sure seems like the standard is to extreme. However, I don't like the thought of 600 gallons per day going down the river.

                        My question is are fish that much more sensitive than humans or are we simply taking better care of them than ourselves?

                        The following was taken from an MSDS for gasoline. Humans are allowed certain levels of exposure as measured in ppm not ppb. FYI, PEL is permissable exposure level and TLV is threshold limit value. Just thought this was interesting.

                        3. Hazards Identification
                        Health Hazard Data:
                        1. The major effect of exposure to this product is central nervous system depression and polyneuropathy.
                        2. Studies have shown that repeated exposure of laboratory animals to high concentrations of whole gasoline vapors at 67,262 and 2056 ppm has caused kidney damage and cancer of the kidney in rats and liver cancer in mice.
                        3. LARC has listed gasoline as possibly carcinogenic (2B) to humans with limited evidence in humans in the absence of sufficient evidence in experimental animals. NIOSH lists gasoline as a carcinogen with no further classification.
                        4. N-heptane and cyclohexane cause narcosis and irritation of eyes and mucous membranes. Cyclohexane has been reported to cause liver and kidney changes in rabbits. N-heptane has been reported to cause polyneuritis following prolonged exposure.
                        5. ACGIH lists benzene a human carcinogen with and assigned TLV of 0.5 ppm 8 hour TWA and a STEL of 2.5 ppm; IARC, NTP $ OSHA show sufficient evidence for classifying Benzene as a human carcinogen, see 29 CGR 1910.1028 for current PEL of 1 ppm and specific actions to take. Studies have shown that benzene can induce leukemia at concentrations as low as 1 ppm. Significant elevations of chromosomal aberrations have been corroborated among workers exposed to levels at mean concentrations less than 10 ppm. Based on risk assessment studies by Rinsky, an individual inhaling 1 ppm of benzene for 40 years, the odds of benzene-induced leukemic death were 1.7 times higher than those of unexposed workers.
                        6. MTBE is a mild irritant to the eye with an LC50of 85 mg/m3 on 4 hr. exposure and an LD50 ~4 ml/Kg (RATS). An increase in anesthesia with increasing concentration (250,500 & 1000 ppm ) was observed during a 90 day Test exposure. ACGIH has listed MTBE as an animal carcinogen (A3) based on tests in experimental animals at relatively high dose levels, by routes of administration, at sites, of histologic types, or by mechanisms not considered relevant to worker exposure. Available evidence suggests that MTBE is not likely to cause cancer in humans except under uncommon or unlikely routes of levels of exposure. 7. Trimethylbenzene (pseudocumene (1,2,4,) & mesitylene (1,2,5,)) has a PEL and TLV of 25 ppm 8 hr. TWA; the isomers may cause nervousness, tension, and anxiety and asthmatic bronchitis.
                        8. n-Hexane has been shown to cause polyneuropathy (peripheral nerve damage) after repeated and prolonged exposure, other hexanes show narcotic effects at 1000 ppm and are not metabolized like n-hexane.
                        9. Toluene can cause impairment of coordination and momentary loss of memory (200-500 ppm); Palpations, extreme weakness and pronounced loss of coordination (500-1500). The 100 ppm 8 hr. TWA and the 150 ppm STEL provides adequate protection.


                        • #13
                          AkCheese and more

                          Well, lets take AkCheese positions one point at a time.

                          There is no provision for mixing zones in Alaska but outboard engines have not been considered a point source for pollution so the mixing zone debate does not apply. A future court case may determine that motors are point sources for the application of laws but to date that has not happened.

                          Not sure what Oregon standard is but Alaska's standard was based on Alaskan fish and waters according to Ms Kent of DEC. She also was the spokeperson who said the standard, based on data, could be lower, not higher. So this is an Alaskan standard, not an Oregon standard. Confusing the issue with standards from states that may or may not set their standard based on science and localized fauna is dangerous.

                          The statement the Pacific Northwest lost their salmon resources to dams and habitat loss is misleading. Most salmon streams in the Pacific Northwest do not have dams. Logging was a major factor but also the urbanization of the environment was a major player. Urbanization results in non-point source pollution just like we are seeing in the Kenai.

                          To imply loss of habitat does not include storm runoff from roads and associated hydrocarbons and other toxic materials is just plain misleading. In addition, what caused the loss of salmon in a number of Northwest streams was not a lack of knowledge on pollution but a lack of will for economic reasons to deal with it or making the choice to give up salmon for economic gain - hatcheries played a major role in that decision making process - they could replace lost fish so one could have their cake and eat it.

                          Agencies were politically influenced and fractured because of different missions and overlapping responsibilities. The same is true for Alaska and the Kenai today.

                          Relative to 2 stroke motors EPA has a list of motors that are 2 stroke compliant. According to DNR and the Watershed Forum there are some 2 stroke motors that meet the compliant standard. You can check with Robert Ruffner or Jack Sinclair on this one.

                          The sensitivity of fish and aquatic organisms to hydrocarbons is well documented, especially juvenile and larval stages of fish. However, the standard is set to protect all aquatic organisms, including the food resources of fish.

                          Finally, in 1992 an ADF&G report by V.P. Litchfield and G. B Kyle entitled Kenai River Water Quality Investigation, Completion Report - FRED Report 123 states " Hydrocarbon analysis of liver samples from sculpin colledted throughout the river indicated that enzyme activity (EROD) was higher in and adjacent to areas of the river that received motorized use (Figure 8). That is, samples from the Moose River, Soldotna Creek, Slikok Creek, and Beaver Creek revealed moderate to high relative levels of enzyme activity (Figure 8), and as compared to induced samples in the laboratory (Paige 1992). Conversely, samples from the Russian and Funny rivers, which are more remotely located from motorized activity, had the lowest enzyme activity. Although limited sampling was done, the results suggest that motorized activity may be associated with hydrocarbon content of sculpin ..."

                          The report goes on to recommend further investigation. So 14 years ago we had an indication of a potential problem with the river. What does that say about priorities and management? Maybe EPA is the only group to save us from ourselves?

                          I also do not own a motor so AkCheese we are just having a difference of opinion here - nothing personal.


                          • #14
                            Bottom line people is.........look at the REAL science

                            *laff* if they're not a point source then what are they? if the emmision from in internal combustion engine is not a point source then you have a real news is the classic definition of a point source.......

                            (*hint* there's only one other choice and that's totally absurd.........that would be a non point source which would be something like runoff from agricultural fields........or an industrial complex)

                            of course if this is going to be addressed as a non point source then this is all really a moot point

                            in any event the Alaska standard of 10 pbb was plucked out of thin air decades ago as many many many "environmental standards" were "back in the day" so called "environmentalists" who couldn't hack it in real engineering or science classes they signed up for "environmental science" (whatever that is)..........nice people.........not much basis in fact........but they did make up a number.........Oregon came up with 100 ppb........Alaska came up with 10 ppb

                            does anybody besides me wonder how it just so happens that the doomsday numbers just happen to be such convenient figures?!?!?!?!?

                            anyhow......these were the same people who told us back in the late 70's that the world would be flat **** TOTALLY out of oil by the year 2000..........(news flash........we are SWIMMING in Oil..........the price is high due to a lot of production and refining issues but there is NO shortage of the raw commodity)............they said we would be OUT of oil for plastics, fertilizer, film, etc..........there would just plain be none left on earth (pause for dramatic effect)

                            one of the most infamous of these divined numbers is ........ a "known human carcinogen" ......... a substance which might cause ONE additional case of cancer in a million people over a standard human lifespan............that number is based on NOTHING........somebody just plain made it up one day.........but it has come to be widely!!

                            *laff* personally I'll take my chances because your chances of getting killed in an auto wreck are CONSIDERABLY higher.........than one in a million

                            Logging results in a loss of habitat.......perhaps more correctly the DESTRUCTION of does urbanizaton.........that's what has led to the demise of northwest salmon stocks

                            those are the main threats to the Kenai river and it's salmon.......have you looked at what's happening to the river banks???

                            nobody is going to tell you that it has ANYthing to do with outboard motors.......because that is just plain absurd.......

                            yes there are SOME 2 stroke motors (very few) that BEGIN to approach the fuel efficiency and pollution control that 4 stroke engines do .......that certainly doesn't in any way negate the plain old FACT that 4 stroke engines pump a LOT less fuel into the water than 2 stroke engines do........

                            anyone who argues the contrary must have a fuel belching 2 stroke sitting out in the yard or has some fishing buddies who do

                            finally the study you cite deals with the liver samples of SCULPIN.......are you serious..........SCULPIN?!?!??!!??! 1992!?!?!?!?...........tell me..........have sculpin stocks on the kenai plummeted precipitously in the last 14 years????

                            good lord if people can't see this for what it actually is then let the games begin.........

                            I think it's going to be hilarious....................


                            • #15
                              AkCheese is losing it.

                              Boy AkCheese you really are off the mark on this one but lets keep trying.

                              First, in Anchorage the air quailty standards are set for the environment over the Anchorage basin. While IM testing can take place at the car tailpipe the standards for clean air are set assuming cars are a non-point source. The same is true for the outboard motors in the Kenai. They move up and down the river and are not point sources per se. Sorry if you do not like this but that is the way it is. Like a car in Anchorage basin the standard is set for the river body not the motor.

                              The standard is reviewed every 3 years by DEC and was not just plucked out of the air. Your characterization is just plain wrong and one must assume that DEC does not do a review with new data analysis for your comment to be correct. You are calling the Director of DEC a liar by your comments. Your personal attack on scientist and environmentalist speaks volumes about bias in your comments against a group of people. I think that is called prejudice.

                              Have no clue what the rant about getting killed in a car wreck means. No one has said anything about lethal impacts on humans. This discussion has been about impacts on aquatic life which impacts the quality of human life if you value salmon and other aquatic fauna.

                              I have looked at the river banks but the main threat to the Kenai will be from development along the river and in our cities. The population of the Kenai has grown to 50,000 from 10,000 over the last 30 years or so. The residential development has resulted in more roads and with it perched culverts when those roads cross tributary streams. A recent culmulative impact assessment done for the Watershed Forum indicated that increased residential development is the main threat to coho salmon production on the Kenai P. You should read the report. Call the Watershed Forum and ask for a copy or at least an abstract. In addition, ubanization brings more people to the river.

                              No one said 2 stroke older motors are not as good as 4 stroke. The conversation was that writing a regulation that prohibits all 2 stroke is not being fair to those who own 2 strokes that are compliant. You said no 2 strokes are compliant - that was incorrect.

                              Relative to owning a 2 stoke motor I do not and have no personal friends that do. I am objecting to those who claim a 4 stoke motor only fishery will solve the fuel problem. With 85% of the motors on the river already 4 stroke the elimination of 2 stroke will not accomplish anything significant. This is the conclusion of DEC experts, DNR staff, and Watershed Forum investigators. The Director of DEC testified to this at the last KRSMA advisory board - are you calling her and her staff names also?

                              Finally, AkCheese you should be concerned about sculpin and fuel levels in their livers. This fish live on the bottom of the river, are resident year round, and may be a very good indicator species of what is happening. To ignore these data from 1992 is very risky. Sculpins and other aquatic fauna can have sublethal impacts from the accumulation of polluants or they can build to levels in the organs to toxic levels for them or other organisms that eat them.

                              No one is measuring population levels of sculpins which may be a major error. Sometimes resident species can tell us more about what is going on than migratory species like salmon. In addition, impacts to populations can be masked by other factors and when those factors change the system fails. At this point everyone then asks what went wrong.

                              AkCheese, you ask why people cannot see what is happening. What is happening? Do you think this is all some type of government plot? People in professional positions are making up things to serve what purpose? This river should have been listed years ago. It has taken 6 years to get this listing - hardly a rush by the DEC or DNR. Do you advocate just letting things go on and ignore this issue? Will you post a bond to compensate this community if you are wrong - lets put your life savings on the line here and see if you really want to take the risk. You are asking a number of people in this community to do that if we proceed without taking action.

                              This is not a funny issue or one you should enjoy as people struggle with how to deal with it. No one should have fun with this as the Kenai River is polluted - plain and simple AkCheese. It is immature to be making this a funny matter when people's incomes are on the line. Let me give some examples of spin off impacts.

                              In 1989 with the Exxon Oil Spill just the threat of oil on a salmon was enough to impact markets for salmon. The State felt the risk was so great they closed fisheries even where the chance of oil was very low. In UCI the commercial fishery was closed because some tar balls were found in the lower inlet. The perception of a polluted system combined with human food harvest made this decision necessary. The risk was low but the general public reacted in a negative way toward the purchase of salmon. If the Kenai River has fuel being dumped in it the perception of tainting of a food resource could be significant. Niche markets like the Kenai Wild program could be seriously impacted. This program depends on certification that water quality of the systems that produce fish are clean, that the resources are sustainable, that quality is maintained in the harvest and processing, and that people belive this is happening.

                              A second industry that may be impacted is the tourist industry. We get people to the Kenai to see wildlife and harvest salmon from pristine waters. Wild Alaska salmon from clean Alaska waters. What will the impact be on tourism if the public perceives or knows that the Kenai is polluted with gasoline? That is another reason we have standards - to keep people feeling safe about the environment they are using and harvesting resources from.

                              This is a serious issue and needs immediate action.

                              I will await to hear what bank you have arranged the bond with AkCheese.


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