Water Update

Rarely-seen inhabitants of the Nooksack River call the alarm.

In 1985, the Department of Ecology adopted an instream flow rule for the Nooksack Basin, covering most of Whatcom County.

Why?

To protect the environment, that’s why.  But don’t take my word for it.  Here’s what the rule says about itself, in its own words:

"The purpose of this Chapter is to retain perennial rivers, streams, and lakes in the Nooksack water resource inventory area with instream flows and levels necessary to provide for preservation of wildlife, fish, scenic, aesthetic, and other environmental values, and navigational values, as well as recreation and water quality." (WAC 173-501-020)

How are we doing?  Well, from 1986 to 2009, the Nooksack River failed to meet instream flows 72 percent of the time during the July-September flow period.  That means that too much water was pumped out of streams, and drawn from the groundwater that feeds into streams, 72% of the time during the dry period.

100% - 72% = 28%.  A grade of 28% is an F.

We’re flunking, big time.  Why are we OK with that?

One explanation comes from opinion-leaders in Whatcom County – the development industry, the Tea Party – who say that the problem isn’t that we are failing to protect the environment by depleting stream flows.  Rather, the problem is the rule.  It’s just that the Instream Resources Protection Program (the full name of the rule) provides too much protection to instream resources.   Instream flow requirements keep too much water in rivers and creeks, they assert.  Cut down instream flows!  The salmon are drowning! 

So they’ve been pressuring the Department of Ecology to adopt a new instream flow rule which, they believe, would allow more water to be pumped out of rivers and creeks, reducing the amount of water left in streams.

On December 3, Ecology presented the WRIA 1 “Planning Unit,” including these self-same opinion leaders (the development industry and the Tea Party), with its assessment of what a new instream flow rule for Whatcom County might look like.  Power point presentations from the program are here (Christensen), here (Wessel), and here (Pacheco). 

The takeaway:  If Ecology adopted a new instream flow rule, more water would have to remain in rivers and creeks in order to meet the goals of preserving fish and wildlife. 

• Our scientific knowledge has increased – for example, we’ve learned that fish actually like water.  Who knew!

• The Endangered Species Act listings happened after the 1985 Rule, so we’d actually have to protect endangered salmon in WRIA 1 if we adopted a new rule.

• Ecology would actually have to comply with state water law if it set a new rule.  All sorts of “new” cases – some of which are a quarter century old by now, but who’s counting – would require additional protections.   Ecology believes that it’s always 1985 in Whatcom County.  A new rule would bring us out of our comfortable time warp and into the harsh environmental reality of the 21^st century.

In short, not only are we failing miserably to keep enough water in our rivers under the 1985 rule, but the 1985 rule wouldn’t protect fish and other resources even if anybody paid any attention to it.

What will Ecology do about this?

As an Ecology representative once said, about Lake Whatcom:  when you’ve dug yourself into a hole, the first step is to stop digging.  But Ecology is not applying that logic to instream flows.

Ecology is arguing in court that the Instream Resources Protection Program is intended to make sure that an unlimited number of new residential wells can draw water from closed watersheds, regardless of their effects on instream flows.  According to Ecology’s argument (which my clients and I think is wrong), residential wells have higher priority than any other water use, even including senior water users such as farmers.  According to Ecology, new residential wells have the legal right to take the very last drop of water from rivers and creeks that are required to be “protected” by instream flows.

I believe that Ecology’s argument stems from expediency rather than conviction.   Ecology knows that water resources are not adequately protected in Whatcom County, but it does not believe that it is equipped to do anything about it.

Look at slide 12 in the Christensen presentation of December 3rd, included in the links above.  Ecology (1) is focusing on Spokane, (2) believes that other counties, some of which have no instream flow rules at all, are even worse off than Whatcom, (3) does not want to have to deal with complying with state water law as it has developed since 1985, and (4) just plain doesn’t have the budget to deal with us.

So Ecology has made it pretty clear – as clear as a bureaucracy can be, on the record – that Whatcom County’s problems are its own.  We have a 1985 rule, and that’s all we get from the state.

“We,” in this context, means Whatcom County.  What is Whatcom County doing to protect water resources?

Whatcom County, along with its allies in the building industry (REALTORS®, Building Industry Association, and Farm Bureau), are fighting in court to avoid protecting instream flows, supporting Ecology’s claim that residential wells have priority over instream flows (and other senior water users) down to the last drop.

The County backed itself into a corner on this issue, of course, by planning for a whole lot of new development outside of cities.  In fact, Whatcom County has planned to allow the equivalent of five new Blaines to be built on agricultural and rural land.  This new development will, for the most part, rely on new wells for water.

The County has no idea whether and where water is available for new development.  It doesn’t want to connect new development to the availability of water, as the Growth Management Act requires.  Fish don’t vote, after all, so there won’t be any repercussions if they are left high and dry.

My clients and I, and Futurewise, are opposing the County’s interpretation of the Nooksack Instream Resources Protection Program.  We don’t think that that the Instream Resources Protection Program says that new residential wells are “exempt” from instream flows.  Here’s a presentation that I gave at a recent legal seminar, with my take on the case.

On December 24^th, we responded to two briefs filed by Whatcom County’s “friends in court,” or “amici curiae.” For those who want to dive into the arguments, here’s the brief that the REALTORS®, Building Industry Association, and Farm Bureau filed to support the County, and here’s our response. 

Here’s the brief that the Washington State Association of Counties filed, and here’s our response.

The Court of Appeals in Seattle will hear arguments on the water case on January 15^th.  If we win, perhaps the County and Ecology might start putting their heads together to figure out how to make sure that land development connects to water quality and quantity.

Win or lose, some water issues are starting to percolate.  So to speak.  County Council member Carl Weimer’s Water Action Initiative may have some results.  Here’s a discussion on Carl’s blog.

Farmers are moving forward to get water.  I assume that a January 8th session on a potential “Whatcom water exchange” is related to this effort (here’s a link).  Bill Clarke, the lead author of the brief filed by the REALTORS®, Building Industry Association, and Farm Bureau, will be speaking, as will a lawyer from Whatcom County’s Seattle law firm, Van Ness Feldman.

It will be interesting to hear what water is available for exchange.  The City of Bellingham and PUD 1 have substantial water rights, making them the logical targets.  Will farmers really tax themselves to pay for the infrastructure that they need to draw water out of the Nooksack?  Or will we all wind up footing the bill?

My prediction for 2015 is that fish and wildlife will continue to foot the bill.  They’re nobody’s constituents.

Next, our children and grandchildren will pay the price.   They’re not voters either.

That’s the remorseless outcome of short-term politics applied to long-term goals and needs.  As our bridges fall beneath us, we shrug and oppose new taxes.  As our water dries up, we shrug and bury our heads in the sand.

We will reap what we sow.

Still Outlaws

The Bellingham Herald reported today that County Council Chair Carl Weimer said "Happy Earth Day."  

This is a stunning development.  After all, Council Chair Weimer's remark stands in stark contrast to the official Whatcom County moniker for Earth Day:  “as [County Executive] Louws called it, National Jellybean Day.” 

Therefore, Q.E.D., the environmentalists are winning.  Everyone, please go back to sleep until the next election.

I wish that I could join the happy siesta.  Truly.  The past four years of County Council mismanagement have worn us all down.  

But the thing is, there's this pending case addressing Whatcom County’s failure to plan for the protection of its water resources in rural areas.  Yes, that case, the one where the Growth Management Hearings Board found that the County had not protected water quality or quantity.

The case that the County lost, although you wouldn’t know it from the folks vigorously asserting the sanctity of the County’s right to continue not to plan.  

These saber-rattlers neglected to address one salient fact:  not only did Whatcom County lose, but it has a current legal obligation to comply with the GMA.    

On April 15, 2014, the Growth Management Hearings Board found that the County remains in noncompliance with the Growth Management Act, because it still has not implemented the planning needed to protect its water resources.  The Board’s “Second Order on Noncompliance” states: 

"Whatcom County is in continuing non-compliance with the Growth Management Act as found in the Board’s June 7, 2013, FDO. This matter is remanded to the County to take action to comply with the Growth Management Act. . .”

The Board requires the County to file a status report in early October 2014, with compliance due on November 21, 2014.

How does the County plan to comply?  Nobody talked about that in the Herald article.

Republican Party leader and Tea Party activist Charlie Crabtree talked about how Whatcom County ought to fight in court because that's what "the party and conservatives" across the state want the County to do.  If the County Council believes that it is under an obligation to uphold the statewide conservative agenda, then so be it  -- and does that mean that the County will continue to thumb its nose at the Growth Management Hearings Board?

Council member Ken Mann asserted that my clients and Futurewise would need to come up with a "profound settlement proposal"  to avoid court.  No word on the County's plans to "take action to comply" with Board's order on water quantity.

Whatcom County is in charge of planning. The County has staff.  The County is the entity that is required “to take action.”

Whatcom County is [still] the outlaw.

I hope that optimism over the new County Council will be justified by words and actions demonstrating that the Council takes its own obligations seriously.   

The responsibility for “profound” proposals to address the County’s ongoing noncompliance with state law ought to be a two-way street.

“Whatcom County Has Plenty of Water,” And Other Happy Talk That Really Isn’t Helpful

This post is a delayed reaction to a panel discussion of Whatcom County water issues that took place last Saturday (this link will take you to Terry Wechsler’s summary of the forum on Northwest Citizen).

One phrase that was repeated umpty-times was “Whatcom County has plenty of water.”  Well, OK.

Let’s think about some other commodities that are plentiful in the County: 

Whatcom County has plenty of money:  Meander through Semiahmoo or Edgemoor, check out the coastal properties off of Chuckanut Drive, and it becomes readily apparent that there is plenty of money in Whatcom County.  I’m betting that we have so much money in Whatcom County that some of it even is sent abroad, to be hidden offshore. 

Whatcom County has plenty of food:  I was in Haggen’s just last night, and the shelves were downright groaning with food.  Farmers grow a lot of food here – milk, berries, all sorts of good things.  Plenty of food.  We even export some of it.  We have so much food that some of it gets thrown away.

And yet, people are poor.  And yet, people go hungry. 

The point is, of course, that overall quantity is one measure of plenty, but it isn’t the most useful measure when distribution is the problem.  And distribution is the problem with water.

Unless and until those winter flood waters voluntarily decide to route themselves into giant natural cisterns, and then accommodatingly flow onto farm fields in August, the fact that we have “plenty of water” (as an annual figure) doesn’t really solve our problem.

OH NO, have I started a meme?  Will people now claim that flood waters will route themselves into previously-unknown natural cisterns, and then will disperse themselves onto farm fields?

My concern is not as far-fetched as you might think.  The statement that got the biggest rise out of the audience last week was farmer Marty Maberry’s announcement that a previously-unknown deep aquifer, “bigger than the Amazon and the Columbia Rivers put together,” had been discovered under Seattle.

Members of the audience (1) immediately thought that he meant “under Whatcom County” (he hadn’t said that, but we all tend to hear what we want to hear), and (2) asked how we can get one of our own.  Marty suggested that we should be putting our money into drilling, so we can discover more previously-unknown deep aquifers.

Well, heck.  Who can blame Marty.  We all want a silver bullet.  And dealing with water issues in this county does have all the fun and sense of achievement of trying to run through a vat of drying cement.   I think that everybody involved is frustrated and would like to be rescued by a giant deep aquifer.

The only problem is that there is no vast, previously-unknown deep aquifer under Seattle.  There is a vast underwater canyon that belches salty, nutrient-laden water into Puget Sound, as my comments on the Northwest Citizen argument explain (with links).  UW researchers recently found that this canyon is bigger than the Amazon and Columbia Rivers, combined.   But it’s no freshwater source.

It’s a bummer.  It throws us back into the vat of drying cement, where none of us wants to be.  But you know what -- we’ve made a big part of that vat ourselves by our heedlessness in ignoring water issues.  The natural world is complex and only getting more so with climate change.  And that’s the reality that we face.

Therefore, I would suggest that it doesn’t help to keep repeating “we have plenty of water” without some clarification.

Who are “we”? Do We the Fishes count?

How do we gauge “plenty”?  Do time-and-place matter?

The state of Washington answered both of those questions in 1985, when it established instream flows (for We the Fishes) and closed watersheds during dry periods.  Yes, fish are part of “we.”  No, “plenty” doesn’t mean that we have enough water when and where we need it.

Almost thirty years later, it’s not like these concerns have gone away.  “Plenty” is as plenty does, and our “plenty” has some strings attached.

So please, no more empty happy talk.  Let’s have some action.

_________________________________

Why is Grumpy Blogger so grumpy?  See the response to Progress Hornsby, below.  

As promised, here's the factual record of Whatcom County's water resource management, in the words of the State Growth Management Hearings Board.  

But hey, this is nothing that Happy Talk can't handle. If we all believe -- REALLY BELIEVE -- that we have the best of all possible County governments. . . . 

if we all snap our fingers and say "Yes, Tink, I believe!". . . . (or, alternatively, "Whatever is, is right," with the theme from Candide running through our minds),

then all these problems just go away. 

"The record demonstrates the following in the County’s Rural Area regarding surface and groundwater resources:

Water Wars Forever

As our loyal readers know, Whatcom County's rural and agricultural areas can accommodate enough new houses to take care of the County's population growth for the next 25 years.  Not one new house or apartment needs to be built in a city -- the County's zoning allows all the new houses anybody could need to be built in rural and ag land.  

And you know that the rural and ag areas don't have water to spare.   Most of the basins in Whatcom County are closed to further withdrawals, but that hasn't affected the County's decision to allow all those new houses to be built, tapping groundwater that will not be available to farmers or to fish.

And you know that the Growth Management Hearings Board has found that the County needs to protect water quality and quantity.  As a result, the County is under a legal compliance obligation; it is supposed to be working towards compliance with the Board's order.  That's the law. 

And you know that the County has the option of improving its water quality and quantity planning to comply with the Board's order. 

Instead, the County Council just voted to spend $40,000 more taxpayer-provided dollars to keep fighting in court.  

And today, in a compliance hearing before the Growth Management Hearings Board (this is a public hearing, so I'm not telling any tales), the County's attorney stated that the "County does not intend to take any further legislative action without guidance by the court."

So much for following the law!

So much for protecting water quality and quantity!
 
So much for all of those campaign promises NOT to keep funding Seattle attorneys to fight against GMA compliance!  I hope that We the Taxpayers are prepared for many more requests for many more tens and hundreds of thousands of dollars, because this Council apparently does not see a need to end the old Council's GMA battles any time soon.

I'm very disappointed as a citizen.  But as an advocate -- well, nobody ever promised us a rose garden, so on we go. 

Whatcom County Leadership Needed to Protect Water Resources and Agricultural Land

The League of Women Voters’ March 15th session on water resources focused on “solutions.”

After the four panel members (Jeremy Freimund, Lumm Water Resources Manager; Hanry Bierlink, representing the Whatcom Agricultural District; George Boggs, from Whatcom Conservation District; and Ann Wessel, from the Department of Ecology) finished their remarks,  the League moderator noted that the speakers had used a whole host of words --  “litigate,” “ cooperate,” “be optimistic,” “be holistic” – and so forth.

As she ran through the string of words, I noticed that one word was missing:  “plan.”  Whatcom County has the obligation to plan to protect water resources.  Why didn’t anybody talk about that?

That absence came out in the subsequent conversation.  Henry Bierlink noted that water “is a land use issue, it’s an economic development issue, and everything else.”

Speaking of planning (or the lack thereof), the next question asked how much farm acreage the County is losing to development.  Henry responded that we lost a lot over the past 20 years, but now it’s plateaued and we have the 100,000 acres that the County Council has committed to protect.

I was standing in the back of the room, shaking my head vigorously – not because I doubt Henry’s word that more than 100,000 acres are currently being farmed in Whatcom County, but because the County has NOT protected 100,000 acres of agricultural land.  Only 88,000 acres are zoned for agriculture (don’t take my word for it – click here and see page 3).

On top of that, even the 88,000 acres that are zoned for agriculture are not permanently protected for agricultural use, as George Boggs emphasized.  The issue, he said is “what we can lose” – and this County has 4,000 development rights in prime agricultural land. 

Why does that matter?  As these lots are developed, they will withdraw some water, and in some places, that may be a problem.  But the bigger problem is the potential for incompatibility.

Unlike anywhere else that I know of, Whatcom County’s zoning allows residential buildings to be built right up to a farmer’s property line.  In fact, under some circumstances, a setback applies to farm buildings, which are constrained in their location in order to protect residential uses.  This is a formula for conflict.

As restrictions tighten on the use of pesticides and other chemicals (don’t take my word for it, click here),   the ever-increasing number of residential buildings in Ag areas will increasingly constrain farming.

Whatcom County has a chance to address this issue in its upcoming Comprehensive Plan update.  It could revise its zoning code and provide some protection to Ag uses.  As George Boggs noted, the issue of residential development in agricultural land is an issue of great urgency. And yet the County Council recently voted NOT to docket a measure that would put the County on the road to protecting the additional ag land that everybody agrees that we need. 

Is Whatcom County in the business of planning?  Reacting?  Merely defending the status quo? 

That leads us to the most profound statement on leadership of the session. Jeremy Freimund, the Lummi Nation’s water resource manager, described the “Lessons Learned” from his years of being in the thick of water resource litigation.  The main “lesson learned,” he said, is that politicians want to be able to say “”the judge made me do it.”

True leadership, as he pointed out, would be to stand up and admit that concessions are needed to get to a negotiated agreement.

I think that we elected a new County Council in hopes that there would be a welcome return to leadership. Perhaps this hope only extended as far as the review of the Gateway Pacific coal terminal, and perhaps we are all too jaded or too indifferent even to dream that Whatcom County will ever again engage in the kind of leadership needed to address our other tough problems.

Water problems.  Council Chair Carl Weimer recently proposed, and the Council recently adopted, a Water Action Plan.  This could and should be part of the solution.  Will it have any teeth?  Will the Council have the political will to buck the status quo? 

The protection of agricultural lands.  Will the County do what it takes?  Ken Mann has proposed a Transfer of Development Rights program to remove development rights from agricultural land.  Does the Council have the technical support, the money, and the backbone to make it work?  And if not, what is Plan B?  Is planning any part of Plan B?

As George Boggs put it, “if you want change, you need to clamor.”  

The Empty Chair at the Water Resource Table

The League of Women Voters hosted an excellent panel this morning.  Five experienced, knowledgeable speakers discussed water resource problems and issues from a variety of perspectives.  The Center for New Media taped the forum, if you missed it (here’s the link). 

Every issue that the panel discussed had to do with the area of the County in which Whatcom County is the sole local general-purpose government – that is, the parts of the County that are not within cities.

There was no representative from Whatcom County.

I do not believe that this reflects a lack of foresight on the part of the League of Women Voters.  Rather, it reflects how far Whatcom County is from playing a leadership role in water issues.

Over the past few weeks, I’ve been asking people with various types of involvement in County water issues if they can tell me who the County’s overall water resource experts are.  (When I say “overall,” I mean “outside of Lake Whatcom.”)  The unanimous answer, from folks in all walks of life and with varied involvement in water issues, has been:

Nobody.

This is quite a recent development that reflects several strands of the County's dominant belief system over the past few years – a lack of a grounding in science (We have more salmon than we know what to do with!  There is no water problem!), opposition to the County’s environmental mandate and obligations (The state can't tell us what to do!  Leave water issues to Ecology!), and a sometimes raucously anti-government ideology (Water law is a communist plot to take away property rights!). As the County has increasingly limited its role to development services, its capacity to address natural resource issues has diminished to the point of -- well, to the point of the answer above.

But without dwelling on the past, the question is:  moving forward, should our most important local general purpose government, Whatcom County, take a leadership role in resolving water resource issues? Or at least be an active participant?

The reaction to a resolution proposed by Council Member Carl Weimer, which asks the County and its partners to develop a “water action plan,” will help to provide the answers to these questions. 

Everybody on the water resources panel seemed to think that it’s a good idea.  Perhaps, if other people support it too, the County will develop the capacity that it needs to be part of the solution. 

And then, perhaps, the League of Women Voters will be able to hold a Water Resources Panel that focuses on Whatcom County's intelligent, proactive approach to addressing its water resource challenges.

Whose County Is It, Anyway?

Sunlight is the best disinfectant.

All right, Pacific International Terminal, Bill Lyne, Gordon Thomas Honeywell, and all you bigwigs who play in the big leagues.  We get it.  You’re big and important, and Whatcom County is small and insignificant.  We are Hicksville, way up in corner of the state, with hardly any people and no significance to your great big important world. Well, other than the fact that our marine shoreline could support a deepwater port that you need for North America's largest coal export terminal. 

But really.  You’ve seen the movie "Braveheart,” right?  You may see us as the rebels with our faces painted blue, beyond the pale of civilization up here in the far reaches of Puget Sound, but do you really expect us to surrender our County to you without a fight?

Let me repeat a fact that sometimes seems to get lost the discussion:  Pacific International Terminal has proposed to locate North America’s largest export terminal in our County. This is one of the biggest projects in the country.  The entire U.S. of A.  Right here in Whatcom County.

When an enormous project descends on a small community, it is not unusual for the enormous project to take over the small community.  After all, project proponents need to make sure that local concerns don’t get in the way.  They have a lot at stake, and the last thing that they need is for the local yokels to putz about, putting big plans at risk with their petty concerns.  And the big guys have the know-how and the wherewithal to keep the locals out of the gears of the machinery.  Right?   

Well, maybe not.  Not necessarily.  That is, if Hicksville really turns out to be Pretty Smart Community With a Bunch of Active, Interested Citizens.

Last week, County Council Chair Carl Weimer proposed a minor amendment to the County Code.  The Code already states that contracts “entered into by the county” (that means the County Executive) over $10,000 must be reviewed and approved by the County Council.  The Council's approval authority currently excludes “pass-through moneys,” or contracts where an applicant reimburses the County.  The Executive may approve such contracts – even if the contracts are in the millions of dollars – without any Council review.

Mr. Weimer’s amendment simply states that contracts “which involve externally funded pass-through moneys” should be approved by the County Council.   That’s all it does.  It eliminates a loophole in the normal system of checks and balances that provides oversight of large contracts.

Why did this simple amendment result in this splenetic three-page bloviation from the lawyer for Pacific International Terminal, the applicant for the Gateway Pacific coal terminal? 

 Why would PIT, a project applicant, insert itself into a matter that’s strictly local, relating to the process for approving a contract?

If everything is on the up-and-up, why would the applicant care WHO reviews the contract, or HOW MANY people review the contract?  

In short, why is PIT afraid of transparency?

According to an article in the Bellingham Herald, Council member Sam Crawford believes that transparency about PIT’s “pass-through” contract would be harmful because citizens aren’t smart enough to understand the role of contracts.  Oversight of pass-through contracts “could create the false impression that the public will be able to convince the council to halt the process over a small change. ‘I think that's too much and that's unnecessary,’ Crawford said of the proposed change to county law. ‘The public may ultimately end up disappointed.’"

So Mr. Crawford and the coal terminal folks just want to protect us from ourselves, to keep us from being “disappointed.”  That’s one possible explanation.  If you agree that the County needs to act in loco parentis, or in the role of a parent that needs to protect its child-like citizens from information, then this makes sense.  I suppose. If that's how you view the role of government.

A letter that David Stalheim wrote to the County Council last week may provide another explanation.     From the information that’s available in public records, it appears that the "pass through" contract doesn't work.  

The County has not actually billed PIT for much time spent on its application.  The record indicates that no county attorney has reviewed any contracts or other documents, the Finance Department has not billed for any time involved in processing contracts or paying bills, and the Public Works Department – which is responsible for stormwater, water quality, and transportation impacts – has spent less than five hours on North American’s largest coal terminal.

What does that mean?  It could just mean that the County’s not very good about keeping time, and that this record-keeping failure means that we the taxpayers are subsidizing PIT.  That’s not very appealing.  

Or it could mean that the County is just rubber-stamping everything that PIT wants to have done, without actually reviewing it or raising any questions.  That is even less appealing. 

Sunlight, which Supreme Court Justice Louis Brandeis called "the best disinfectant," would reveal whether or not there is a reason for concern.  And sunlight, in the form of public transparency, could not conceivably hurt anyone involved in the contract – assuming that the contract is shipshape, aboveboard, well monitored, and in the public interest.    

So, if you think that it ought to be OK for the public and the County Council to see what’s happening in the contract between PIT and Whatcom County, please write to the County Council and support Council Chair Weimer’s resolution. The Council's e-mail address is council@co.whatcom.wa.us. 

Or attend the Council meeting on Tuesday, February 11th.  The Finance and Administrative Services Committee will consider the proposed amendment at 11:00 (the public may or may not be allowed to speak, but you can at least listen to your policy-makers debate the issue), and open session will start shortly after the meeting begins at 7:00 in the evening.  The agenda is here.   

If you think that PIT knows best how our County should be run, then by all means, support PIT.

Either way, we’ll know whose County this is.