As I mentioned in my last post, Coastkeeper supports the mayor’s proposed rate hike, but we find the U-T‘s Nov. 22 editorial on the subject odd, to say the least. First, it counsels against the mayor using a rate hike for upgrading Point Loma to secondary sewage treatment or implementing reservoir augmentation (affectionately dubbed “toilet-to-tap”) programs. The funny thing is the mayor has specifically said the proposed rate hikes are not earmarked for either of these projects, so I’m not sure where this editorial came from, or where it is going.

But onto the merits of its claims … starting with Point Loma, which treats and discharges approximately 170 million gallons of wastewater to the ocean. Point Loma has an exemption that allows it to do less treatment (advanced primary) than more than 16,000 sewage agencies nationally. In fact, Point Loma is the only waiver-holder left standing in California, and it discharges more sewage than the other 33 waiver-holders left in the country combined.

In order to get a 5-year waiver, which must next be renewed be June 2008 (with paperwork due in December 2007), the burden is on the city to demonstrate (among other things) that upgrading to secondary is economically or technologically infeasible and that it is unnecessary as there is no harm to the ocean. To repeat, the burden is on the city to prove these points.

During the past waiver application, the city continued to claim that upgrading Point Loma was impossible, to get to secondary would require new treatment facilities that would cost between $2 billion and $10 billion, and that Scripps studies demonstrate conclusively that there is no hard from Point Loma. If I agreed with these points, which are still picked up upon by the U-T, I would also agree that upgrading Point Loma is an unnecessary waste of money.

But a funny thing happened on the way to our next waiver – everybody (the city, Coastkeeper, Surfrider, Sierra Club) sued over the last waiver and discharge permit. As a result of our legal settlement, the city undertook a pilot study that proved that Point Loma could be upgraded to secondary and that it would cost far less than initially estimated – a total of $500M at the completion of the study, now $700M because of increased construction costs. There may be new technologies on the horizon that could reduce this cost even further, and we have already approached federal and state agencies (which bore up to 80 percent of costs for most of the state’s sewage plant upgrades) to see if they could provide matching grants to ease the burden on local ratepayers.

As part of our legal settlement, the city and environmental groups also convened a technical committee of leading experts on ocean health, including Scripps, to review the existing monitoring plan so it could be improved. The group reached the conclusion that while the city has fully implemented the required compliance monitoring program and has even undertaken special studies on the health of kelp beds near the outfall, the current program is not nearly robust enough to truly assess the impacts of 170 million gallons of sewage being discharged into our ocean daily. We have not studied deep ocean impacts (the discharge is near a deep canyon), plume migration of the sewage discharge, prevalence of viruses or endocrine disrupters, or impacts from the discharge on marine mammals. In short, the scientists involved in this assessment agreed that we cannot say conclusively whether there are impacts from Point Loma on ocean health.

This puts Coastkeeper in an interesting (and I would say fairly strong) position going into the next waiver application. With a presumption that agencies should treat sewage to secondary standards, the burden on the city to demonstrate infeasibility and lack of impacts, and environmental groups holding studies that show costs to upgrade are far lower than previously estimated and a panel of experts saying we do not know if there is harm, I feel pretty good about challenging the next application at our regulatory agencies or, if need be, in court.

I certainly hope it never gets that far. In all our discussions with city officials, we have been very understanding that upgrading Point Loma should be a lower priority than the immediate needs of fixing our collection system. An upgrade could then happen after the current infrastructure capital campaign is completed in 2013, at which time we might have more conclusive evidence of impacts from an enhanced monitoring program. We have also already started taking a lead in identifying state and federal dollars to assist the city in our time of need.

Likewise, city officials have suggested to us a willingness to try to reach a solution so we can work out an agreement that is acceptable to all parties (and does not compel us to fight a waiver application in court). But the U-T‘s bomb-throwing does nothing to help us reach a resolution that will protect ratepayers as well as our ocean environment. While I have again run out of time and space, I must briefly address reservoir augmentation (RA), which was a big part of my first posts on in August. Suffice it to say, when meeting one-on-one with our top officials and presenting the current state of evidence on RA (namely, that it is safe and will help reduce our dependence on imported water that already receives literally 400 million gallons of sewage discharges daily before reaching San Diego), environmentalists are assured that these leaders understand and agree with this project on public policy, fiscal and environmental grounds. They simply believe a massive public education effort is needed so our communities understand where our water currently comes from and why the proposed project is, in the long term, needed, cost-effective, and safer than our current supplies.

The interesting thing, though, is that none of these leaders actually want to lead on this public education front. With the resources at their disposal (admittedly not what they once were), and the bully-pulpit they can use (again, not as pronounced as it has been), city officials are still well-positioned to help undertake a campaign aimed at increasing understanding of our local water needs. Instead, they want to hand this role off to small groups like Coastkeeper to do the heavy-lifting.

I am certainly willing to do my part, but also call on our elected officials to publicly repudiate the U-T‘s counter-productive editorial and take a leadership role on these issues so we can continue to move ahead and make ourselves America’s Clean Water Capital.

So much for a short post …


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