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Breaking the Bank for the Wrong Bay Cleanup Plan
A Summary of Santa Monica Bay Cleanup Issues By Rex Frankel, Director, Ballona Ecosystem Education Project
1. OUR GOAL: 35 years after the passage of the U.S. Clean Water Act, our local government is finally talking about a specific plan to make Santa Monica Bay beaches swim-able and healthy again. Unfortunately, the Plan on the table for the Los Angeles and Santa Monica City portions is an overpriced and ineffective boondoggle. The debate over this project boils down to a choice between building up to 24 mini-Hyperion treatment plants throughout the City at a minimum cost of $9 billion or adding up to 24 new parks, re-creating wetlands and flowing creekbeds, bringing much needed green space to this dense city, that will likely cost a lot less in the long run.
We express our criticism not to halt Bay cleanup, as some have tried, but because we really want the project to succeed. We fear that the high costs and lack of quantifiable results in the City's current approach could lead to a taxpayer revolt, and consequently, more delays in the Bay cleanup.
Our primary interest is to see concreted-over creekbeds be daylighted, or opened to the sky as they once were, and spring back to life throughout the City so that natural processes can clean urban runoff. Unfortunately, the L.A. City runoff cleanup plans use questionable math to make it seem that Santa Monica Bay will be kept clean. Two recently released plans, the first known as the Integrated Resources Plan for the entire City, and the second known as the Santa Monica Bay Beaches Bacteria Implementation Plan, are, in their present form, simply very expensive projects with little actual benefits for the environment, despite how they have been described since their inception. It does not have to be this way. This scenario could be played out differently. Our beaches could be cleaned up by creating a connected network of parks and creeks flowing through the City. The billions of dollars that would be spent on 24 huge water treatment plants could instead go to re-greening the City which was paved over in the last century. The economic boon brought by revitalized communities could be the same as in many other urban areas that have chosen to regreen the hearts of their city, encouraging businesses and neighborhoods to face the river instead of turning their backs to them and fencing them off. This could be a plan that pays for itself. Or it could be a huge tax on the residents of L.A., with a minimum of $100 to $400 a month bill for each household. (NOTE: References in this report are to the Draft Environmental Impact Report for the Integrated Resources Plan (IRP), the IRP Facilities Plan volumes 1-4 (both available at http://www.lacity-irp.org), and the Santa Monica Bay Beaches Bacteria TMDL Implementation Plan and technical appendices, available at http://www.waterboards.ca.gov/losangeles/html/bpaRes/bpa_td/bpa_40_2006-006_td.html . The acronym TMDL stands for Total Maximum Daily Loads of water pollutants.)
2. WHY THE JOB IS SO MUCH MORE DIFFICULT
IN LOS ANGELES Currently, the City of Los Angeles has 220 miles of open river and storm drain channels and 1900 miles of underground storm drain pipes. (Facilities Plan volume 3, page 3-7). Most of these channels are concrete, steel or other non-natural material. Unlike other nearby urbanized areas that are also largely built-out, Los Angeles has the disadvantage in that most storm channels are closely hemmed in on both sides by development. In the two areas we analyze in this section, runoff contacts unpaved, somewhat natural landscapes while flowing out to sea. Therefore, pollution levels are usually less severe. One interesting discovery is that the law does not require beaches and rivers to be clean all the time which reduces the size of the job the City is required to do. The Water Board has decided that due to the fact that natural sources of bacteria cause health code violations on 17 days a year, based on a nearly undeveloped canyon in Malibu they use as a reference site, the City of L.A. must reduce violation-days from the current 30 or so per year to 17. So their job is a lot easier. The City’approach for compliance therefore is to ignore the 17 largest days of runoff per year, thereby needing to manage only 25% of the total runoff. They propose to do this by capturing all runoff from storms that are .45 of an inch or smaller, which is the size of the average 18th largest rain-day per year. ( How they will know the size of a storm beforehand to determine whether to catch the water I am not sure. Also, rain-days are defined as a day with rainfall equal to or greater than 0.1 inch plus the next three days) THE IRVINE MODEL: We have looked to the City of Irvine Natural Treatment System which uses wetlands instead of conventional treatment plants to clean urban runoff as the ideal project to emulate. (See http://www.naturaltreatmentsystem.org for more information.) There, however, they have the advantage of unpaved drainage channels with ample parks next to the creeks, and so huge amounts of concrete do not have to be removed. They will be able to use the vegetation at the bottoms of the creeks and some offline basins for treatment. Because Irvine was developed since 1970, after passage of the federal Clean Water Act and State laws which protect wetlands, they also could not put their creeks (which at the time largely functioned as agricultural irrigation drains) into concrete boxes on the wide scale as has occurred in L.A. These laws which protect wetlands did not exist at the time L.A. was developed. THE SOUTH BAY CITIES: The heavily urbanized beach cities southwest of Los Angeles spanning from Manhattan Beach to Torrance are markedly different from L.A. in terms of severity of water pollution problems. Despite that the area is completely built out, (in fact the last large vacant parcel was developed in the 1980s --Manhattan Village), beach water quality violations during wet weather are mostly not a problem, with only one drain outfall in violation. While dry weather flows are frequently in violation, this is relatively easy to fix, and in fact, six of the drains with the most dry weather flow violations are in the process of being diverted during the dry season only to the County sewage treatment plant located in the City of Carson. It is likely the reason this region is less in violation is due to geography. The south bay cities lie upon rows of sand dunes, and rainfall naturally collects from developed land into a series of natural basins or sumps between the dunes. Each basin has a drain pipe tunneled towards the ocean. It is likely that vegetation in these basins absorbs pollutants. It is unusual, in fact, that wet weather flows in the South Bay are less in violation than dry weather flows, even though wet weather flows normally carry the most pollutants in urban areas. To read more about the South Bay Cities cleanup plan, go to this website: http://www.waterboards.ca.gov/losangeles/html/bpaRes/bpa_td/41_New/SMBBB%20TMDL%20Implementation%20Plan%20JG%205-6.pdf HOW L.A. IS DIFFERENT: In L.A., we are handicapped in that anything we do is going to displace some existing urban feature, and therefore will cost an enormous amount of money, whether mechanical or natural treatment is chosen, unless vacant land is used. Complicating things, the L.A. Unified School District has been on a massive building boom and has grabbed, developed and therefore, paved over at least 100 new school sites in the last 5 years at locations, some of which could have been ideal for water management facilities. 3. THE L.A. SANITATION DEPARTMENT
PREFERRED PLAN; THE NUMBERS DO NOT ADD UP
Because available vacant land is so scarce, the L.A. City plan, therefore, places a lot of hope on prevention of pollution, or what they call source control. The plan envisions a lot more street-sweeping, or street-vacuuming, and installing a lot of filters and trash screens on storm drains. The plan emphasizes catching the rainfall that falls upon parks, schools, undeveloped hillsides and other government lands as a way to reduce the amount of polluted runoff, spending around $1 billion to do this. Future developers will have to retain their runoff on-site and clean it up. Through these measures, the IRP has the ambitious goal that it will manage 47% of runoff. While well intentioned, these source-control concepts do not add up to catching very much of the polluted runoff. For example, since most parks are grassy fields, the ground naturally absorbs the rainfall, and what does runoff is not very polluted. The IRP EIR in fact gives no numbers for what source-control is going to actually accomplish. The Santa Monica Bay TMDL Implementation Plan technical reports also give little credence to the ability of source-controls to make much of a difference. Finally, expecting future development to solve the pollution problem is not realistic since most of the City is built-out. These concepts seem like feel-good measures that the City has put forward to buy time and avoid making the hard choices, which are: (a) their fallback plan, building highly mechanized and expensive pollution cleanup plants, or (b) our proposal, acquiring private land to create water-holding basins and treatment wetlands next to rivers and creeks. In order to buy time, L.A City planners must convince the State Regional Water Quality Control Board that a delay will allow the City to offer many green benefits, in what is called an integrated plan. The goals of an integrated plan go beyond catching polluted street runoff to include greater re-use of water (sewage and runoff), which could lead to less reliance upon imported water sources, plus it should include natural pollution cleanup methods that could use parks and open space. In allowing this extension of time, the water board stated the City integrated plans should include the goals of environmental justice; parks, greenways and open space; and active and passive recreational and environmental education opportunities (source: 12/12/02 TMDL attachment A, page 6, footnote 4, which can be found at http://www.waterboards.ca.gov/losangeles/html/bpaRes/bpa_td/40_New/Appen%20B.pdf) . This will extend the deadline to comply from 2013 to 2021. Because public works projects often take many years to carry out, if the City has in fact spent the last 3 years on a plan that will not cleanup the Bay, and then has as a fallback plan one that will be prohibitively expensive, then we have a really big problem here.
ARE THERE ULTERIOR MOTIVES IN THE IRP? SEWAGE PLANT EXPANSION IS ON THE FAST-TRACK; RUNOFF CLEANUP IS ON THE BACK-BURNER The goal of an integrated plan, to quote the City, is to take into account the 'relationship between wastewater, drinking water and stormwater service function and the potential for mutually beneficial approaches in context of watershed planning'.
By integrating how the City manages its various water resources, City planners hope to do more than catching and cleaning storm runoff so that it does not cause violations of health standards in open creeks and the ocean. They also hope to: 1. expand the sewage treatment system capacity by up to 9%, and 2. expand the drinking water supply by up to 7.4% by catching rainfall, and cleaning and reusing sewage and runoff, leading to reuse of 50% of the storm runoff But the IRP does not contain specific plans to clean up the City water pollution problems, postponing them to some unknown future date. In the IRP, it is stated 'because the majority of the (pollution standards, known as) TMDLs are not published yet, the intent of the IRP is not to ensure TMDL compliance but instead it focuses on maximizing runoff management opportunities to supplement water supply needs, and in the process improve the water quality of the receiving water bodies.' (IRP Facilities Plan volume 3, page 2-3, also page 3-12 in which it is stated that a 'detailed implementation plan will need to be developed to address full compliance with the regulations'.) DOES THE DRINKING WATER AND SEWAGE PLANT EXPANSION ENCOURAGE MORE URBAN GROWTH? In what the Plan claims is a runoff cleanup measure, much effort is being made to capture as many clean sources of water as possible from undeveloped hillsides and canyons, from roof tops and parks, schools and government sites all before it is mixed with street runoff. This could be seen more as a way to expand the City drinking water supply than as a pollution-cleansing method. In my experience, whenever the City talks about conserving water, it does not mean the City is going to then stop taking so much water from the Owens Valley aqueduct. In the past, only lawsuits have forced the City to do that. Without a firm promise to import less water, the added water supply and sewage treatment enhancements of this plan give lip-service to sustainable standards, but are inevitably adding more capacity for further urban development. 4. HOW MUCH IS IT GOING TO COST? RIDICULOUSLY INFLATED COST STUDIES BY CLEANUP OPPONENTS Some opponents of cleaning up the Bay have authored studies that claimed the cost for L.A. County could be between $50 and $250 billion. These studies were based on treating every drop of runoff to drinking water standards using reverse-osmosis technology, which is not what the Clean Water Act requires. The unstated, but obvious, purpose of these studies was to encourage a backlash by voters and taxpayers, so that no cleanup at all would occur. STRATEGICALLY UNDERSTATED COST ESTIMATES BY THE CITY On the other hand, cost estimates by L.A. City are unrealistic in the other direction, by understating the costs. This fits another strategy, which is to get voters to start the project going, thinking costs will be reasonable, and once the project is only partially built, the taxpayers are told the actual price. But since they have already invested a lot of money, they can not back out now or the money already spent will have been wasted. In 2004, voters approved paying for the first $500 million of the runoff cleanup program. In newspaper stories on the IRP, City officials described its cost as around $3 billion. This cost estimate is in the text of the IRP, which describes each of the IRP components as costing around $1 billion for each of the sewage, water supply and runoff cleansing measures, for a total of about $3 billion. However, this only includes cleaning the storm runoff from about 10% of the City only, a fact that has not been publicized. The IRP in one place mentions cleansing runoff for the entire City, which will cost around $9 billion if the City uses conventional treatment plants. But while this is described as a worst-case scenario, City planners and elected officials are forcing it to happen by approving major development projects on every possibly feasible runoff-managing site.
A COMPARISON OF PLANS FOR CLEANING UP
LOS ANGELES' STORM RUNOFF:
SCENARIO ONE: SCENARIO 2: SCENARIO 3: SCENARIO 1: Integrated source reduction approach as proposed in IRP and TMDL Implementation Plans SCENARIO 2: End-of-the-pipe treatment plants as described in IRP and TMDL Implementation Plans SCENARIO 3: Unpave rivers and corridor of lands alongside rivers and creeks to create treatment wetlands CITYWIDE COST $10 to $15 Billion $10 to $15 billion Unknown, likely high EFFECTIVENESS Complies with TMDLs Complies with TMDLs DOES IT MEET MULTIPLE BENEFIT GOALS OF INTEGRATED APPROACH? Barely if at all. While it may use natural methods to clean runoff, by using existing public lands for most facilities, it contradicts the original goal of Prop. O, which was acquisition of greenbelts along the No Yes ARE SPECIFIC SITES STUDIED IN THE IRP AND TMDL IMPLEMENTATION PLANS? Yes. 10,000 cisterns are proposed at schools and government facilities in the IRP. Many more cisterns and treatment BMPs are proposed at parks in the TMDL implementation plans Yes, up to 24 diversion and treatment plants throughout the City No. In fact, this concept is not studied at all in either the IRP or TMDL Implementation Plans. In the meantime, developers and LAUSD are paving or planning to pave over most available sites for this scenario or Scenario 2 DOES IT INCLUDE CREATION OF PARKS AND WILDLIFE HABITAT? No, in fact it poses conflicts with existing uses of recreation lands No Yes IMPACTS VS. BENEFITS Digs up parks, school playgrounds and government sites for cistern projects. Converts some parks into runoff treatment sites. May expand the drinking water supply slightly. Creates network of treatment plants around City Creates numerous parks, encourages attractive sustainable redevelopment of neglected areas along rivers with waterside amenities which could help the project pay for itself No. High cost and little visible benefit. No. High cost and no visible benefit Yes. ------------------------------------------------------------------------------------------------- END-NOTES:
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