Sanitation Districts’ Commitment to Health, Ecology Unfairly Slighted

On June 18 you published a commentary by Patrick C. Wall concerning the county sanitation districts’ application for continuation of their ocean discharge waiver (“Moving the World Is a Loner’s Job”). Mr. Wall’s apparent disinterest in the truth and his misrepresentation of the facts are a real disservice to any ecologically minded citizen or organization having a sincere interest in and dedication to responsible overall environmental management and protection.

First, the article incorrectly states that the districts dump partially treated sewage offshore. We provide a blend of 53% full secondary treatment and 47% advanced primary treatment, which meets the strict California state requirements and those established by the Environmental Protection Agency under the provisions of Section 301(h) of the federal Clean Water Act, which allows the ocean discharge of a high-quality but less than full secondary effluent for only those treatment plants that can prove their discharge will not adversely affect marine water quality.

Contrary to the statement in the article, the districts have never allowed the dumping of untreated sewage into coastal waters. Further, there is absolutely no buildup of solid residuals on the ocean floor, and there is no visible damage around the outfall, as Mr. Wall contends. In fact, the outfall itself is teeming with marine life and resembles an underwater reef. Fish caught off Orange County’s coast meet all Food and Drug Administration standards.

Likewise, the statement implying a preference for disposing of sludge at landfills over recycling is inaccurate. Just a few short years ago, all of our sludge was trucked to a landfill. Today, almost two-thirds of it is safely recycled by composting or direct agricultural land application. We expect to reach our goal of 100% recycling in the near future. Incidentally, the marketplace does not pay for sludge; sludge disposal costs the districts more than $3.3 million per year. The reality is that the cost to transport and process sludge means we cannot sell it for a profit. Therefore, an increase in sludge quantities resulting from full secondary treatment would actually increase ratepayers’ costs.

With regard to the removal of toxic materials from our discharge, industrial-source control of toxics is the cornerstone of our program. We have successfully controlled the discharge of pollutants to levels that are so low that the raw sewage entering our waste-water treatment facilities is actually better than the effluent discharge standards for full secondary treatment imposed by the EPA and the state of California on our ocean discharge. Over the last 15 years, we have reduced the discharge of toxic materials by 80%.

Mr. Wall also erroneously implies that we will expand our treatment capacity only if required to provide full secondary treatment to all of our flow. We have an ongoing construction program designed to meet the environmental and sewage needs of our service area and currently have $205 million worth of facilities under construction, another $170 million worth under design, including additional secondary treatment, and $112 million worth in the planning stages. The program will cost $1.5 billion by the year 2020.

When deciding if we should construct full secondary treatment facilities, we cannot conscientiously justify to our taxpayers an additional $1.4-billion expenditure (more than doubling the residents’ costs) for a nominal increase in removal of organic solids when scientific data gathered over the past five years through a $10-million ocean monitoring program provides evidence indicating that public health and the marine environment are now being protected. The local marine ecosystem simply is not threatened by the districts’ program. Eminent scientists from the Scripps Institution of Oceanography have argued that full secondary treatment for deep-ocean dischargers would be a waste of taxpayers’ funds.

Full secondary treatment also has significant adverse environmental effects. These include more effects on land from sludge disposal, increased energy use, much greater depletion of natural resources and more air emissions.

In an era of diminishing natural resources, increasing oil imports, air-quality concerns from energy generation, the greenhouse effect and regional transportation problems (trucking sludge, for example), there is a need to look at the national and global picture to put things into perspective. The basic laws of ecology mandate that we look at the macro consequences of our actions--not just the micro effects.

The governing body of the sanitation districts is composed of dedicated community leaders, council members and board members representing the 24 communities and unincorporated territory and the 2.1 million constituents served by the districts. I can assure you that they take their responsibilities very seriously. Only after weighing the preponderance of scientific, engineering and economic evidence compiled by an independent team of consulting experts did the districts’ boards of directors determine that continuation of their existing waste-water management program, which operates pursuant to the strict provisions of the federal Clean Water Act, is in the best overall interests of the citizens of Orange County. It will enable us to continue to maintain fishable and swimmable coastal waters in an efficient, effective manner.

The districts’ directors and staff take great pride in our many accomplishments. We are recognized as one of the leading waste-water management agencies in the country. The success of our programs in protecting public health and the ocean resources off Orange County’s coastline and providing balanced, total environmental management is supported by the results of our ongoing ocean monitoring and research programs and is exemplified by the numerous federal, state and regional awards of excellence the districts have received.

A.B. CATLIN, Chairman, Joint Boards of Directors, Orange County Sanitation Districts, Councilman, Fullerton City Council