Voluntary Clean Water Guidance for Agriculture

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Comment From: Whitman County (Art Swannack)

12/06/25 @ 12:35 AM

Dear Dept of Ecology,
I have several comments on the draft plan.
Regarding agricultural tillage and residue management practices--In eastern washington and central washington, the residue levels you advocate for will cause major problems with s...↓eed germination and weed and disease pressures. With winter wheat, to get a good stand you need moisture near soil surface, otherwise you will get erosion due to lack of growing plants holding soil together. farms get from 8" to possibly 18" of rainfall per year. The areas with 18" can do no till successfully but only until weed/disease/resistance to herbicide issues occur, then they need to be able to do mechanical control through tillage to reduce the problems to manageable levels. They will possibly return to no till or min till within a few years, but expecting no till or very slight tillage to be successful as the only method of farming shows a lack of knowledge about cropping and agronomy. I also believe this would violate the second part of rcw 90.48 regarding use of available and reasonable methods, as forcing a method which significantly reduces yields is not reasonable. I also note with regards to the second half of the tillage and residue document, your cited locations have different rainfall patterns (summer majority rainfall) than the Pacific Northwest where most of our rainfall is received from October through April and vastly different cropping abilities than eastern washington due to total higher rainfall, humidity and temperature regimes. I don't believe they are scientifically valid examples to support your assertions.
Regarding buffer requirements on ephemeral non fish bearing streams which are claimed to reduce water temperatures, in the eastern Washington farming areas those ephemeral streams only exist from October to April and then are dry. During the times they exist the air temperatures are not high enough nor days long enough to cause the water to have temperatures which harm salmon. Any requirements for buffers on ephemeral non fish bearing streams in these areas need to be site specific rather than generally applied, show water present during periods when air temperatures are high and the science for the site must support water presence during higher temperature periods.
The Voluntary Stewardship program is a viable and useful tool to help with overall watershed quality. We do not need mandatory buffers on every inch of stream to solve the water temperature or tmdl sediment issues. There is too much ideology and not enough practicality in this proposal.
A similar comment to crops applies to the idea of no livestock ever being allowed in riparian areas. There is feed in riparian areas for mammals. If you eliminate livestock, then the e. coli levels will still go up because there are more wildlife using the area. And as shown in California when wild pigs moved into leafy green vegetable fields at night, wildlife can cause serious e.coli outbreaks in humans. I would recommend a plan where livestock are given reasonable access to riparian areas, but limit the amount of forage they can remove, much like a forest service or BLM lease is managed. Then have them move to another area. And by the way, during the growing season, wet riparian areas will have vegetation grow back quickly--it isn't gone forever like concrete and streets destroy riparian areas in cities.
I will note the federal clean water act policies regarding non point pollution are not regulator, they are recommendations. There are practical reasons why VSP was implemented to help maintain and enhance agriculture viability while protecting riparian areas and watersheds as a whole at 2011 or better levels. There will never be the funding to operate a regulatory program at the level of enforcement proposed by this plan, at either the state or county level. It is unrealistic to expect such funding. I believe you should take a step back, encourage use of VSP and get your wins on a watershed basis there.
I'd also note, that at the last riparian roundtable, the tribal interests stated they are only looking for 80% of riparian areas to be in good condition and they know it would cost too much to try and regulate everything. this comment was from the Western Washington tribes. I believe you need to consult with Eastern Washington tribes regarding non-point pollution, how they plan to handle it on their lands and develop a strategy for the state as a whole that is realistic and affordable.
I'm going to conclude with this comment. The idea that buffers need to be as wide as the tallest tree in the area (SPTH) is a taking of property and prevention of use. The state would need to provide financial compensation in perpetua for such a taking to the landowners. It is also questionable that you can justify the taking vs the benefit to salmon of requiring such restrictions. You don't need perfect buffers, you need practical buffers that people can live with. Get rid of the SPTH theory and work on what does a good enough job. Often that is the first 30ft of riparian.
sincerely
Art Swannack
Whitman County Commissioner

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Comment From: Pat Morton

12/05/25 @ 9:21 PM

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