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Kenai River DEC comment period on impaired listing

Marcus

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Deja vu. . .

Deja vu. . .

You're welcome. Here's how I see what's happening. Some years back, an Alaska legislator told me the single biggest reason the Feds took over game management on federal land in Alaska was the Alaska Outdoor Council's dogged resistance to a subsistence priority. The same thing is before us on the Kenai River.

No amount of talk about how it used to be, where the samples were taken, or whatever is going to change the fact that pollution standards have been consistently violated on the Kenai River. Some doggedly resist that fact, trying to find a way around it — ain't gonna happen. Some, unbelievably, even want more use of the Kenai, more sportfishing, more motors, etc. In the end, it doesn't take a genius to figure out you can't build a growth industry or business on a finite resource.

Nor are guides the problem. Guides are a part of the problem, a significant part of the problem, and they will be part of the solution as will all other user groups: private anglers, the PU fishery, and so on.

The new group, KAFC, is a sign of the times, a concrete manisfestation of area anglers and state and federal fisheries professionals finally being pushed far enough to push back. No one can or will ignore KAFC member's 120 years of scientific and biological experience on the Kenai (I am not a member). Stifled and silent for long, they are neither any longer.

The Kenai River is impaired. This is the twilight of unbridled expansion of the Kenai's sportfishery.
 
R

robryan

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..for a minute there I thought it might be important to bring some additional support to the effort, ....silly me, I wasn't aware that additional backing was so unnecessary.
 
R

robryan

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...the intended humor.

...sorry, the intent wasn't to unsettle you.
 

Marcus

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KRSMA board supports impaired listing. . .

KRSMA board supports impaired listing. . .

November 20, 2006

Drew Grant
Alaska Department of Environmental Conservation
PO Box 11180
410 Willoughby Ave. Suite 303
Juneau AK 99801

Re: Kenai River Impaired Waterbody Status

Dear Mr. Grant:

By notice dated November 1, 2006, the Department of Environmental Conservation asked for public input regarding its proposal to list a portion of the Kenai River as impaired under Section 303(b)5 of the Federal Clean Water Act. The Kenai River Special Management Area (KRSMA) Advisory Board has a long history of concern over water quality in the Kenai River. In fact, the KRSMA Advisory Board sponsored and endorsed the water quality studies that revealed the exceedences. After receiving briefings from DEC and the Kenai Watershed Forum, and after receiving public input, The KRSMA Advisory Board endorses the listing of the Kenai River as impaired subject to the provisions and limitations discussed in this letter.

The KRSMA Advisory Board believes it is important to accurately describe the short duration and limited geographic area involved with the exceedences in order to develop remedial measures which solve the problem with minimal adverse impacts on user groups. As we understand the facts, the exceedences involve an undetermined number of days during July when sport fishing for king salmon is at its peak and angler effort is highest. The exceedences occur on days with the greatest concentration of motorized boats are fishing for king salmon and particularly during flood tides when the flow in the river is backed up. We understand that the hydrocarbon pollution is the direct result of discharge from outboard motors and the problem has worsened over the last six years. The area affected is the portion of the river from Mile 19 to the mouth of the river. We further understand that the July personal use fishery for sockeye salmon at the mouth of the river (outside the KRSMA boundary) contributes to the problem.

Notwithstanding the short duration and limited area of the problem, the KRSMA Advisory Board believes that the hydrocarbon pollution is a serious problem which must be eliminated as quickly as feasible. During our last meeting on November 9, 2006 a DEC representative estimated a Total Daily Maximum Load (TDML) would not be formulated and implemented until 2011. This time frame is wholly unacceptable to the Board. Accordingly, the KRSMA Advisory Board initiated a public process to develop action steps to alleviate the problem more expediently. In, fact, the Board has already taken several affirmative steps that should help alleviate the hydrocarbon problem. In 2005, the Board endorsed the buy back program for older two cycle outboards. In April and September 2006, the Board asked the DNR to ban outboards not complying with 2006 EPA standards (mostly two-cycle outboards) in 2008. In October 2006, the board formed a special committee to accept public input and develop plans to reduce hydrocarbon emissions with recommendations to be completed by spring 2007.

The KRSMA Advisory Board appreciates that other difficult steps will be necessary to fully resolve the problem. To that end, the KRSMA Advisory Board is committed to working diligently on this problem and invites active participation of the DEC, ADF&G, the Cities of Kenai and Soldotna to work with the Board and DNR. By working together and sharing information, the Board and the agencies can move expeditiously to help preserve the habitat of the Kenai River and its unique fishery that is important to all Alaskans.

If you have any questions, lease feel free to contact the Board.

Very Truly Yours,


Ken Lancaster
President, KRSMA Advisory Board

Cc: DNR Commissioner
ADF&G Commissioner
City of Kenai City Manager
City of Soldotna City Manager
Kenai Peninsula Borough
 

fishNphysician

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Environment Canada's Environmental Technology Centre (ETC) has conducted tests on two-stroke outboard engines for a variety of compounds formed through the combustion process. The tests showed that two-stroke outboards produce 12 times as many of certain types of hydrocarbons as four-stroke engines, and five times as much oil and grease.
The ETC also compared exhaust emissions from a light-duty van, a 9.9-hp two-stroke outboard and a 9.9-hp four-stroke outboard.

The two-stroke also emitted 15 times more unburned hydrocarbons than the four-stroke and nearly 125 times more than the van.


That means that even if 2 strokes only account for 15% of the craft on the water, they will contribute nearly 3/4 of the unburned fuel spilled into the river. For those who doubt the math, here it is (x = amount of fuel spilled by one 4 stroke motor).


85(x) + 15(15x) = total fuel spilled.
85x + 225x = total fuel spilled.

310x = total fuel spilled.



225x/310x = fuel spilled by 2 strokes = 73% of total fuel spilled

85x/310x = fuel spilled by 4 strokes = 27% of total fuel spilled


Get rid of the 2 strokes and you will eliminate the problem immediately.


Irrationally yours...
 

fishNphysician

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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.

I believe the analysis in the post above de-bunks that assertion.
 

Nerka

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changed my mind

changed my mind

Posted a response to fishNphysician calculations on the other thread but I have come to the conclusion that the two stroke engine issue will reduce hydrocarbons signficantly under certain assumptions. However to reduce the hydrocarbons from 20 ppb at river mile 1.5 will take action in the PU fishery, stop the growth in the upriver fishery, and keep the horsepower at 35 instead of 50.

Let me explain - I maintain that the levels that will be reduced will be about half of what is out there today with the 2 stroke fix. It could be lower or higher as there is significant uncertainity in the calculations. This only applies to the upriver fishery.

So if one takes 12 ppb (just a starting point for discussion) and reduces it by half to 6 pp at the Warren A. Bridge then to keep below 10 ppb at river mile 1.5 the PU fishery will have to be reduced to 4 ppb. Since the PU fishery is presently contributing about 10ppb that fishery will need a significant change - whether it is four stroke engines or a different type of fishery.

So when I said it will not accomplish anything significant I did underestimae the impact of two strokes if the assumptions are correct about fuel use. However, there are some questions in the data set which brings the assumptions into play. For example on the peak day when 20ppb was measured a high number of boats were below the bridge. If most of those were two stroke then the fuel levels should have been much higher at river mile 1.5. Not having the boat counts I think this is one area that needs better data. The total boat count was 700 so there must have been at least 200 or more below the bridge.

For the time being I am willing to go with a 50% reduction upriver but feel that it is a very soft number relative to keeping all sections of the river below 10 ppb.

Hey doc, got you with that "irrational" comment - in the interest of catch and release I am let you off the hook.
 

yukon

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What about the commercial fishermen, refueling docks and general input? While in the PU fishery I have personally witnesseds sheens coming from some commercial boats that are anchored. Has anyone discussed their potential imput the the tide water hydrocarbons. This issue as well needs attention and needs it be addressed if indeed they are found to be a contributer.
Good info doc. Lets "pick the low hanging fruit" and take the first step in getting rid of 2-strokes, and for the record I will have to by 2 new motors when the regulation takes effect.
This issue will not get solved in one action by anyone or board. It will take different steps and regulations, this, I am sure, is just the first but potentially the most effective.
 

Marcus

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Easy pickin's . . .

Easy pickin's . . .

Lets "pick the low hanging fruit" and take the first step in getting rid of 2-strokes, and for the record I will have to by 2 new motors when the regulation takes effect.

If access to and enjoyment of the public resource that is the Kenai River fishery can be pictured as a tree with fruit for all to enjoy, then indeed 2-stroke powered access — older mom-and-pop motors for the most part — is the easiest to enjoy, the lowest on the tree, and the easiest to lop off.

 

yukon

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Marcus of all people you know better, please do not twist my words and make it sound as if I wanted to kick "mom and pop" angler off the river. You have taken my comment completely out of context and I do not appreciate you insinuating that I want to "lop off" mom-and-pop motors for the most part. That is an insult to me and putting thoughts out there that I clearly did not state, plain and simple, twisting my words to make your, not my, point.

It is obviouls 2-strokes put in over 10 times as much hydrocarbons as 4-strokes, git rid of them, no matter who uses them, including me.
 

Marcus

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My apologies. . .

My apologies. . .

yukon, my apologies if you're offended or insulted. Note that while I quoted your metaphor, including the part about cost, and developed it, I did not use your name nor ascribe the quote to you in any fashion. I used the idea, I did not personalize it.

Your metaphor was apt, I merely rounded it out. Maybe I could have waited until a few more posts intervened between yours and mine. Please forgive me.

That said, you're right, older, inefficient 2-strokes must go. In fact, they'd go on their own, given enough time, in accordance with the second law of thermodynamics. But we're in a bigger hurry than that it would seem. Some want the old 2-strokes gone by 2008. Some, a bit more flexible, are willing to wait until 2010.

What's your take? How quickly do you think the 2-stroke need to go?
 

yukon

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If cost was not an option, 2007, I could live with 2009 although IMO 2008 is the right year. I am amazed that many, not necessarily you, want to reduce hydrocarbons and make the river healthier but are not willing to take the first step of getting 2-strokes gone. A sacrifice for some, including me, yes, but those are the motors that are doing the most input of hydrocarbons. A two-stoke at idol, ecpecially a non-oil injected model is very inefficient.

What do people want, to have a cleaner river now or in 4 years??????

My answer is now.

BTW, you personalized it by quoting me (even though you didn't use my name it doesn't take a genius to figure out where it came from LOL). Forgiven
 

Marcus

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Thanks. . .

Thanks. . .

No, it doesn't take a genius to figure out where I got the quote. . . should have waited for some posts to intervene. See. . that's what you get for coming up with such a clever metaphor. . . got me too excited to think straight.

Let's move on: I think most people realize the old 2-strokes have got to go, but let's go easy. Don't folks with big boats have something like 10 years to get rid of them?

Everyone wants a cleaner river; it's imperative we get a cleaner river or the Feds will do it for us just as they're now managing some of our fish and game because we waited too long. But understand that mom and pop have a hard time taking it in the ear while others want bigger motors. That just plain sounds wrong!
 

yukon

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It is not just bigger motors, that is not the issue, it is reduced wake (accomplished by 50 according to the wake study) and 4-strokes to reduce hydrocarbons. Data was asked for in the discussion and Doc produces (as usual) as far as hydrocarbons goes. So two problems are being mitigated by this proposal, erosion and hydrocarbons, win-win.

Just a thought for discussion and I am in no way supporting this but.....

What would the discussion be if we didn't have the data from the wake study supporting a reduced wake with 50 hp and this was squarely a hydrocarbon issue.
With the premise of cleaning up the river would the same arguements be put forth if the proposal was not for 50hp but just 4-strokes with a max of 35?

Marcus, so are you saying, you are willing to allow the build up of hyrdocarbons over the next 3 years in order to save mom and pop's outboard?
I say 3 years is too long to wait and the Fed's will intervene in that time, IMO. To me the Fed's stepping in is just plain wrong.
 

Marcus

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Not like I hear it. . .

Not like I hear it. . .

yukon: No one's arguing that a 4-stroke doesn't burn cleaner than a 2-stroke. That said, there is no data that I know of that says that going 50-horsepower motors will reduce erosion and hydrocarbon emissions into the Kenai. None. If fishNphysician can mess with the math to say otherwise, then he's sharper than DEC, DNR, and Kenai Watershed Forum put together. Come on now. . .

Sorry, but I don't understand your question regarding 35-horsepower 4-strokes.

No, I'm not willing to allow hydrocarbon build up in the Kenai by allowing more time to phase out the two strokes. How's that going to happen? No one's going to go out and buy more old motors. The 2-strokes are disappearing on their own, more are being removed by the current buy-back program, and more will go as owners realize they must. Be a little patient for heaven's sake. You never did tell me how long the big boats have to phase out?

In my opinion, yukon, the 50-horsepower thing is total malarkey — a ridiculous and hypocritical pandering to commercial users. Makes no sense whatsoever. Who in their right mind can believe more is less? Who in their right mind can accept that mom and pop get the shaft while at the same time others get bigger motors? The public just ain't that dumb.

If you're really so afraid of the Feds jumping in that quickly, why on earth would you even want to chance going to 50s when there is no data whatsoever that says such an increase won't actually increase pollution?

A 50-horsepower increase is a bad, bad move with ominous implications for the future of the river and much more. Bad.
 

yukon

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Don't worry about my senario, not a big deal.

The wake studies show that 50hp throws an average of 12% less wake.

As far as 2-strokes disappearing on their own, what is the time frame, I have one from 1965 that I run on the river. How long are you willing to wait?
I believe boats over 21 ft. have until 2010, I am not positive but pretty sure.
More is less because we are using motors that are not designed for that use, the motor is not running in optimum conditions and therefore is not as efficient.
I can accept as you say "mom and pop get the shaft(including me)" if it will have signficant effect on the hydrocarbons. "Others" are not getting bigger motors, just running them effeciently as designed.
I only brought up the Fed's because you inserted them into the equation.
I see why no one likes to bring data into the conversation because it quickly gets dismissed.
Does anyone know where DEC got it's data that Nerka quotes? Did DEC run tests or did they just make the assumption that since 50hp is a certain percentage more than 35hp then it must put in that much more % of hydrocarbons?

And yes, Doc is probably smarter than any of those groups.

So is your answer "yes" to the question: "Marcus, so are you saying, you are willing to allow the build up of hyrdocarbons over the next 3 years in order to save mom and pop's outboard?"
 

fishNphysician

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In my opinion, yukon, the 50-horsepower thing is total malarkey — a ridiculous and hypocritical pandering to commercial users. Makes no sense whatsoever. Who in their right mind can believe more is less? Who in their right mind can accept that mom and pop get the shaft while at the same time others get bigger motors? The public just ain't that dumb.

If you're really so afraid of the Feds jumping in that quickly, why on earth would you even want to chance going to 50s when there is no data whatsoever that says such an increase won't actually increase pollution?

A 50-horsepower increase is a bad, bad move with ominous implications for the future of the river and much more. Bad.

Any supposed increase in emissions from going from 35 to 50 hp will be more than offset by the reductions achieved via elimination of older 2-strokes.

The 50 hp motors are already on the water, it's not like the majority of 4 stroke users will go out and buy a bigger motor.

There is no commercially available 35 hp motor. Detuning a bigger motor is the most common way to get around that, but at the cost of reduced efficiency. By going to a 50 hp maximum, the motors that are already mounted on the vast majority of the boats presently in use can be made to run more efficiently, thus potentially reducing actual total fuel burned at the end of a long fishing day. Less fuel consumed, less fuel spilled.

A lot of boats on the water "plow" while underway, creating huge wakes. As has been repeated, 50 hp would allow those boats to get on plane, reducing wake and reducing erosion. Moreover, there is a dramatic jump in fuel efficiency the moment a boat gets up on plane. A boat that plows burns tremendously more fuel to get from point A to point B. Again more fuel efficiency, less fuel consumed and less fuel spilled at the end of the day.

And taking the "exacerbation of social problems" into consideration... smaller boats, lighter loads, fewer trips will create burdens of their own... the majority of them falling on the shoulders of guides and the guided user. I'm not saying that user group should be exempt from sharing the burden, but their concerns should be part of the equation.

Without addressing angler demand, tinkering with smaller boats, lighter loads, and fewer trips may actually end up backfiring. If you still end up having to accomodate the same number of anglers, they just show up in more boats... only this time smaller and lighter. More vehicles burning more net fuel, and thereby spilling more net fuel into the river. The carpool/mass transit analogy posted elsewhere in these threads was very astute.

I'll have to agree with yukon, the 50 hp/4-stroke proposal is a win-win... less wake and less hydrocarbons. The hypothetical risks are small... and clearly outweighed by the obvious benefits.

Get the thing passed, then let's get to work on reducing angler demand.
 

Marcus

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I'm tired. . .

I'm tired. . .

Guys, I think I'm going to rest my case about here. I'm too old and too tired to keep on endlessly hashing over the same tired arguments.

The big-motor, more-is-less, don't-restrict-commercial-use, there-is-no-problem, get-rid-of-the-2-strokes-now crowd have their point of view, stated over and over and over on this and other threads as has been mine.

Unless someone comes up with something new, I going to go read a good book.

This is going nowhere, and I have much more pleasant ways to waste my time.
 

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