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HomeMy WebLinkAbout18 - Irvine Ranch Water District (IRWD) Wetland Water Supply ProjectBY THE CITY CGo- k CITY OF NEWPORT" C3LACH November 27, 1995 (I�i NOV 2 % 19% UTY COUNCIL AGENDA ITEM NO. 18 U. MAY UK ANU MEMBERS OF THE CITY COUNCIL FROM: PUBLIC WORKS DEPARTMENT SUBJECT: IRVINE RANCH WATER DISTRICT (IRWD) WETLAND WATER SUPPLY PROJECT RECOMMENDATION: If desired adopt Resolution No. 95- , expressing opposition to the proposed Irvine Ranch Water District Wetland Water Supply Project. DISCUSSION: On November 13, 1995, City Council received a status report on the Irvine Ranch Water District (IRWD) Wetland Water Supply Project (Project) and directed staff to bring back a resolution expressing opposition to the Project. The Project, if approved, would discharge 5,000,000 gallons of tertiary treated waste water per day into San Diego Creek and ultimately into Upper Newport Bay during the fall and winter. The City has retained experts to evaluate the Project and related environmental impacts on the Bay. The City Council has also obtained public input in various forums regarding the Project. The public has been overwhelmingly opposed to the Project. Copies of letter reports from biologist Joy B. Zedler, Ph.D., and Dr. Peggy Fong, and Water Engineering Modeler, Gib Bogle, are attached for Council review. Each report has a very short staff summary attached. IRWD has expressed the intention of proceeding with certification of the Environmental Impact Report (EIR) on December 4, 1995. Certification of the EIR would effectively foreclose the City's ability to have IRWD consider information obtained from the City's experts. Resolution No. 95- , expresses the City's opposition to the Project until such time as the City Council and the public are assured that the Project will not have an adverse impact on public health, bay water quality, or the environment. Respectfully submitted, PUBLIC WORKS DEPARTMENT Don Webb, Director Attachments s i RESOLUTION NO. 95� "'"'� "»""" "".'.y "�`.""."`"`_. r' • .• A RESOLUTION OF THE CITY COUNCIL OF THE CITY f OF NEWPORT BEACH EXPRESSING OPPOSITION TO THE PROPOSED IRWD "WETLAND WATER SUPPLY PROJECT." WHEREAS, the City of Newport Beach is home to more than 10,000 small boats and has the largest small boat harbor on the West Coast; and WHEREAS, in addition to being the largest small boat harbor, Newport Bay offers unparalleled public recreational activities such as swimming, sailing, fishing; and WHEREAS, Newport Bay and neighboring ocean beaches attract millions of visitors each year and these visitors are essential to the Newport Beach economy; and WHEREAS, the Newport Beach City Council and many Newport Beach residents have, for many years, been engaged in efforts to improve Newport Bay water quality, and Newport Bay has been designated a "no discharge" harbor because of its heavy recreational usage and the potential impact of discharges on the public health, safety and welfare; and WHEREAS, the Newport Beach City Council and many residents have engaged in a public information and education campaign to eliminate discharges that adversely impact Bay water quality and inform the public of recent improvements in Bay water quality; and WHEREAS, the Irvine Ranch Water District (IRWD) has proposed a "Wetland Water Supply Project" (Project) which would, if approved, discharge 5,000,000 million gallons of tertiary treated waste water per day into San Diego Creek which will flow into the Upper Newport Bay during the fall and winter; and WHEREAS, the City Council has retained experts to evaluate the Project and related environmental documents to determine if the Project could have a significant impact on Bay water quality, flora and fauna in Upper and Lower Newport Bay, and the potential for adverse effects on public health and welfare; and WHEREAS, reaction to this Project by Newport Beach residents, and the public generally, has been overwhelmingly negative with many questions regarding the adequacy and accuracy of the environmental document prepared by IRWD, in conjunction with the Project; and WHEREAS, many informed citizens question the conclusions in the environmental documents regarding the potential public health and water quality impacts of the Project; and WHEREAS, IRWD has expressed the intent to proceed with certification of the environmental document on December 4, 1995, prior to the date on which City of Newport Beach will receive reports from all experts on the potential impacts of the Project on Bay water quality and human health; and WHEREAS, certification of the EIR would effectively foreclose IRWD's ability to consider information from experts retained by the City of Newport Beach prior to certification of the EIR for approval of the Project; and WHEREAS, the City Council of Newport Beach intends to oppose the Project unless and until the Irvine Ranch Water District has established with certainty that the proposed Project will not have any adverse impact on public health, or any adverse impact on flora I or fauna in Newport Bay. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Newport Beach is opposed to the "Wetland Water Supply Project," and will remain opposed until the City Council and the public is convinced that the Project will not have adverse impact on public health, bay water quality, or the environment, and the City Council will take all action necessary to protect the public health, safety and welfare of all persons who could be adversely impacted by the discharge of tertiary treated waste water into Newport Bay. ADOPTED, this day of November, 1995. ATTEST: CITY CLERK wb\reso1\irwd.res Public Works Departr—nt Summary Gilbert Bogle Ph.D, Letter Report on Modeling Dr. Bogle offered the following comments regarding modeling after reviewing the IRWD EIR for the Wetlands Water Supply Project. It is doubtful whether the TC III 1 - dimensional model used for the EIR is capable of making accurate predictions of salinity or NO3 in an absolute sense, but the model predictions are still likely to be useful in a relative sense. After running his own 2-dimensional model Dr. Bogle concludes that while the two models differ somewhat in the levels of Nitrate that they predict throughout the bay, they agree qualitatively in the prediction of the effect of the IRWD discharge. WZMMA WATER ENGINEERING & MODELING 766 North Mentor Avenue Pasadena, CA 91104 (818) 398-9735 (Tel. & FAX) October 23, 1995 John Walter Public Works Department City of Newport Beach P.O. Box 1768 Newport Beach, CA 92658 Dear John, The following is my review of the numerical modeling performed as part of the EIR prepared for the Irvine Ranch Water District to assess the impacts of the proposed discharge of treated wastewater into Newport Bay via San Diego Creek. The report is in two parts. The first part concerns the characteristics of the Branched Tidal Channel Model (TC111) model used in the study, while the second part compares results reported in the EIR with those obtained using another model, for two basic cases. TC111 Model Review As a preface, I would like to point out that most of the limitations of the TC111 model that are discussed here are also acknowledged in a Technical Memorandum that was an appendix to the EIR. Newport Bay is a complex hydrodynamic system, particularly the upper reach. The appearance of the upper bay changes dramatically from high tide to low tide, as the extensive shallow areas are left exposed by the receding water. At low tide the flow is in the relatively deep channels, which could reasonably be represented as having rectangular cross-section, as is done in the TC111 formulation. However, as the water level rises the cross-section departs markedly from a rectangular shape. The TC111 model, as a one-dimensional treatment, is forced to constrain the channel cross-section to be rectangular. The area of the cross-section in the model is forced to conform with the actual area at two points in the tidal cycle - low tide and high tide - and interpolation is used to fix the dimensions of the rectangular channel at all intermediate water levels. Coupled with the very coarse discretization of the upper bay into only 8 channel segments, it is clear that the geometrical representation of the bay is extremely. crude. One would have to say that this is probably the simplest possible numerical model of the bay. In some parts of the bay, the simple treatment of the geometry does not depart very much from reality, but in the upper end of the bay the omission of wetting and drying of shallow areas is a major limitation. The geometrical assumptions make it necessary to ignore features like the Newport Dunes embayment, the constriction of the flow at the gap in the Salt Dike, and the channel loops that occur in several places. Because the bay is short in comparison to a tidal wavelength, water surface elevations throughout the bay track the variation in water surface elevation at the ocean boundary (with a time lag that depends on distance from the ocean entrancq). This means that provided the cell dimensions were correctly specified (not possible to verify, but presumably true), the model is capable of correctly predicting the total flow volumes in and out of the different parts of the bay as the water surface elevation varies between low and high tide. There is no guarantee that the volumes will be correct for intermediate tidal stages, however, because the linear interpolation that is used to compute the channel widths from water depth will in general not yield the correct cross-section areas. For this reason velocities predicted by the model can not be expected to be reliable even as cross-section averages - in any case the fact that a channel segment or cell usually represents a section of the bay with a varying cross-section means that the modeled velocities are averages along as well as across the channel. The fact that the TC111 model is oriented towards reproducing flows rather than velocities is consistent with the water quality part of the model, which effectively treats the bay as a set of tanks, each fully mixed, with flows and mixing between adjacent tanks. This is obviously a great simplification of the reality of transport and mixing in the bay. The foregoing comments focus on limitations of TC111 which are the limitations of any one-dimensional model in the estuarial context. Implicitly, the model is compared with a two-dimensional depth -averaged model such as RMA2, which has the capability to represent the geometry to the desired level of detail, including in the case of the RMA2 model the wetting and drying of mudflats. There is another serious limitation of the one-dimensional approach which is shared by depth -averaged two-dimensional models: the vertical variation in density that results from freshwater inflows into a saline bay. At low levels of inflow from San Diego Creek, there is a tendency for the less dense inflow to float on and flow over the surface of the denser water in the bay, which has a salinity approaching that of seawater. It has been shown that this leads to the creation of a saline "wedge", a situation in which the isohalines (surfaces of equal salinity) are tilted at a considerable angle from the vertical (which is the orientation they 2 would have if the bay were well mixed vertically). Near the upper end of the bay the isohalines can become almost horizontal. No depth -averaged model can account for this effect, and in fact it presents a rather intractable problem with the current state of /- numerical models. While the above criticisms might be interpreted as severe, they must be placed in the context of what is required and expected of a model of this kind. TC111 could be looked upon as a kind of level 1 model (leaving aside strictly analytical approaches), in a ranking in which a two-dimensional depth -averaged model would be level 2, and a full three-dimensional treatment (which may not be available yet) would be level 3. Stepping from one level to the next implies a significant increase in difficulty, data requirements, and cost. Depending on the issues to be studied, a simpler model may be adequate for certain purposes, even if its accuracy is known to be limited. At this point the issue of calibration becomes important. The TC111 model includes two parameters (friction coefficient and mixing coefficient) that can be varied to adjust the model performance in order to improve agreement with measured data, i.e. to calibrate the model. The EIR reports that the model was relatively insensitive to the friction coefficient, which is to be expected in this case, particularly since shallow areas have been eliminated from the model. The main calibration "knob", therefore, is the mixing coefficient. The modelers adjusted mixing while simulating steady state low flow conditions, using salinity as the modeled water quality constituent. Using available historic salinity data, they arrived at a value of the mixing coefficient that matched resulted in model predictions of salinity that were as close as possible to the measured salinities. For this exercise the San Diego Creek flow was held at a steady level that was estimated to have existed at the time of the salinity measurements. This procedure was conducted for two periods of relatively constant stream flow. The streamflow levels are not reported, but it seems likely that they were 16 cfs and 45 cfs. All the details of the salinity -based calibration are not available, but it appears that the salinity at the upper end of the bay (cell 58, Unit 1 Basin), was used as the main calibration target. The report is a little confusing because it appears.that different results are reported in different places. Focusing on a steady stream flow of 16 cfs (dry winter conditions) and assuming 34 ppt ocean salinity: Table 3.3-9 shows salinity in cell 58 as in the range 26.7 - 30.0 ppt over a tidal cycle, while Table 3.4-3 (revised) indicates that the range of variation in cell 58 (Unit 1 Basin) is 23 - 31 ppt. Calibration in the Newport Bay is a rather thorny problem, for five reasons. First, only a limited number of simultaneous flow and salinity measurements are available. Second, many of those 3 measurements were taken when the amount of sediment in the upper basins was different from what it is now, and salt water intrusion into the upper bay is affected considerably by the channel depth. Third, long periods of constant stream flow are required to calibrate the model, because it takes the bay many tidal cycles to return to equilibrium (in the salinity distribution) after it has been disturbed. To be most useful, measurements need to have been taken after such steady flow periods. Fourth, because of the variation of salinity over a tidal cycle (which near Jamboree Road is much greater than that predicted by TC111), it is necessary to take salinity measurements over a full tidal cycle. This is seldom done. Lastly, since the numerical models that are being used and are likely to be used in the foreseeable future in Newport Bay assume full vertical mixing (i.e. are depth averaged), the salinity measurements used to calibrate the models should also be of the average salinity throughout the water column. In a final calibration step that was relevant only to nitrate, measured nitrate concentrations were used to set the nitrate decay rate in the model at 0.005/day. The suitability of TC111 to the task of modeling salinity and nitrate levels in Newport Bay is put in question because of the simplifying assumptions used in the model, particularly the one- dimensional approximation, which severely distorts the geometry of the bay. The shortcomings of this particular model must be kept in perspective, however, considering the difficult modeling issues that must be confronted regardless of the modeling approach adopted: calibration with incomplete data and the problem of density stratification at low flows. It is doubtful whether TC111 is capable of making accurate predictions of salinity or NO3 in an absolute sense, but the model predictions are still likely to be useful in a relative sense. To give an example, if the model predicts (as it does for the IRWD 7.7 cfs discharge) that a particular scenario will result in reduced nitrate levels everywhere in the bay, it is probably predicting the direction of change correctly. Whether the model correctly predicts the actual nitrate levels, or the magnitude of the change in nitrate level at any location, is much more open to question. 4 RMA2/RMA4 Modeling of Salinity and Nitrate in Newport Bay Water Engineering & Modeling developed hydrodynamics (RMA2) and water quality (RMA4) models of Newport Bay in 1992 as part of a previous study conducted for the USACOE. A report of the modeling was released as Appendix G to the Upper Newport Bay Reconnaissance Study. That appendix contains a description of the models, a picture of the finite element grid used in the model, and graphical depictions of model results. Briefly, the RMA2 model uses a two-dimensional depth averaged formulation to solve the equations of motion (depth averaged Navier Stokes equations) for currents and water surface elevation over a region of arbitrary shape. The finite element method allows the geometry of the region to be represented to any desired level of accuracy, and the model can account for the wetting and drying of shallow areas. The companion model, RMA4, solves the convective -diffusion equation that governs transport of a dissolved constituent, using the hydrodynamic results from RMA2. The hydrodynamic model was calibrated using data from a water surface elevation and current measurement program conducted by Coastal Frontiers Corporation. At that time, the lack of suitable data precluded calibration of the water quality model, and the model was run with typical parameter values used in other estuary studies. For the purposes of comparing the salinity and nitrate results predicted by the TC111 with RMA model predictions, a rough calibration of the RMA4 model was performed using the results of salinity data analysis performed by John M. Tettemer & Associates, on OCEMA measurements. This calibration effort was conducted at short notice and should be considered provisional, and all the reservations expressed in the foregoing about salinity data apply. The crux of the problem, as faced by the TC111 modelers, is to choose salinity and flow measurements that represent steady state conditions. From the results reported by Tettemer, it was estimated that a steady flow of 16 cfs in San Diego Creek is associated with a mean salinity (tidally- and depth -averaged) of about 26 ppt in the middle of the Unit 1 basin (cell 58 in TC111). This was used as the target in the calibration. In an attempt to account for the surface flow of fresh water near the top of the upper bay, which has the effect of increasing the rate of lateral mixing of the freshwater inflow, elements in that area were given mixing parameter values much higher than those in the rest of the bay. Nitrate decay was incorporated by using the same decay rate of 0.005/day that the TC111 modelers adopted. Two cases have been modeled for comparison with TC111 results: Case A: existing conditions with 16 cfs flow in San Diego Creek and a nitrate level of 16.3 mg/L (this is the calibration condition), Case B: 16 cfs base flow + IRWD discharge of 7.7 cfs, 1 mg/L nitrate, giving a net San Diego Creek flow of 23.7 cfs, and a 0 nitrate level of 11.3 mg/L. To facilitate comparison with the TC111 model results, locations have been selected in the middle of each of the TC111 cells (RMA4 computes concentrations at nodal points rather than averages over regions). In the tables that follow, the locations have been labeled by the corresponding TC111 cell number. For each location, the tidal average (mean), the tidal low value (min) and the tidal high value (max) of the concentration is reported. Table 1 shows the salinity results for the two cases, and Table 2 shows the nitrate results for the two cases. Table 1. Modeled salinity at selected locations for winter low flow: existing conditions and 7.7 cfs IRWD discharge (1 mg/L). Cell Existing Conditions IRWD Discharge 7.7 cfs No. Mean Min Max Mean Min Max 58 23.2 13.3 26.6 20.5 10.2 24.5 57 25.8 21.5 27.6 23.4 18.6 25.7 56 27.0 25.6 28.2 24.9 23.2 26.4 55 27.8 26.8 29.2 25.9 24.6 27.7 54 28.9 27.4 31.4 27.4 25.4 30.5 53 30.1 28.0 32.2 28.9 26.2 31.5 52 31.1 28.9 32.7 30.2 27.3 32.3 51 31.9 30.0 33.0 31.2 28.7 32.7 50 32.6 31.7 33.3 32.2 30.9 33.1 40 33.2 32.3 33.8 33.0 31.8 33.8 30 33.6 32.7 34.0 33.4 32.2 34.0 20 33.7 32.9 34.0 33.6 32.6 34.0 80 32.4 32.3 32.4 31.8 31.8 31.8 70 32.4 32.4 32.4 31.8 31.8 31.9 60 32.4 32.3 32.5 31.9 31.7 32.0 11 Table 2. Modeled nitrate concentration at selected locations for winter low flow: existing conditions and 7.7 cfs IRWD discharge (1 mg/L). Cell Existing Conditions IRWD Discharge 7.7 cfs No. Mean Min Max Mean Min Max 58 5.06 3.40 9.78 4.48 3.15 7.91 57 3.83 2.94 5.87 3.49 2.74 5.09 56 3.25 2.68 3.91 3.01 2.51 3.86 55 2.88 2.21 3.35 2.69 2.09 3.11 54 2.33 1'.19 3.04 2.19 1.14 2.84 53 1.76 0.83 2.75 1.67 0:81 2.58 52 1.32 0.58 2.26 1.26 0.56 2.22 51 0.96 0.44 1.85 0.92 0.43 1.75 50 0.62 0.30 1.05 0.61 0.29 1.01 40 0.34 0.07 0.75 0.33 0.07 0.72 30 0.20 0.02 0.59 0.19 0.02 0.58 20 0.12 0.00 0.48 0.12 0.00 0.46 80 0.73 0.72 0.74 0.72 0.70 0.72 70 0.72 0.71 0.73 0.70 0.69 0.71 60 0.70 0.65 0.76 0.69 0.64 0.74 The salinity results in Table 1 are to be compared with the TC111 results in Table 3.3-9 of the EIR. The two sets of results are similar. The TC111 model has been calibrated to give slightly lower salinities at the top of the bay. The RMA4 results near the top of the bay show a wider spread between the high and low values of salinity over a tidal cycle. That is a reflection of the fact that TC111 averages salinity over a wide region, which has the effect of reducing fluctuations. Both sets of results show a similar amount of salinity decrease with the change in streamflow from 16 cfs to 23.7 cfs. The existing conditions case in Table 2 corresponds to Case I in Table A-1 of the EIR, while the IRWD discharge case in Table 2 corresponds to Case IV in Table A-2 of the EIR. The RMA4 results exhibit more variation from low to high values at each location. The RMA4 concentration gradient is slightly greater than the TC111 gradient, with significantly higher values at the top of the bay and slightly lower values near the ocean entrance. Like the TC111 results, the RMA4 results indicate a reduction in nitrate levels everywhere in the bay with the addition of a 7.7 cfs, lmg/L IRWD discharge. In summary, while the RMA4 and TC111 models differ somewhat in the levels of nitrate that they predict throughout the bay, they agree qualitatively in their prediction of the effect of the IRWD discharge. 7 UCCR Biology Department TEL: 310-206-3987 No- 21,95 10:45 No.004 P.03 the model that is changing under the different water flow conditions is the mlxing alit flusiliiig componente. Not only has this assumption never been tested, but there is a large body of experimental evidence that demonstrated that "community" nutrient uptake rates vary greatly seasonally, year-to-year, and with changing environmental conditions that will co-occur with increased freshwater flow. Thus, this lends significant uncertainty to model predictions. Evidence from laboratory and field experiments have shown that algal community composition changes dramatically under different salinity, water flow, and nutrient regimes. For example, in my master's i found that lowered salinity favors Enferomorpha over phytoplankton and cyanobacteria. Different algal communities have very different net nutrient uptake capabilities, so can not be considered constant des under different salinities, influx/efflux from the sediment changes s highly dependent on water flow rate. 2. 1 acknowledge that my work with Enferomorpha has been in microcosms or mesocosms that mimic closed systems. That is because historically nuisance blooms have had the most impact in these systems, and I wanted to determine the ecological processes controlling bloom dynamics. However, this work is the only of its kind for southern Californian coastal systems. i would never claim that the results of an experiment mimicking a closed system are directly applicable to an opon, tidally flushed system. On the other hand, the results of my experiments suggest that increasing nutrient supply to any system should not be done without a careful study of the This would entail experiments with algaeenot there senardata fon of or experimentter sumn nutrient addressing addressing these concentration. At present, issues in local open systems. Thus, there is no local evidence to support the "no impact" statement based on reduced water column nutrients. 3. The authors of the EIR repeatedly make the statement that algal growth is dependent on water column nutrient concentration, and even go so far as to say that a Monad growth curve based on water column nutrients is the appropriate formulation. I do not know a phycologist in the world that still uses this formulation. It is a convenient approximation for PHYTOPLANKTON growth, and was used extensively in early modeling efforts in the 1970's. It is still a good approximation for deep phytoplankton-based systems like Narragansett Bay or the Chesapeake. However, it is completely Inappropriate for any model relating to macroalgae macroalgal dominated nutrient storage plays a significantole In growth and biomass accumulation. has been work In many parts of the world showing the lack of relationship between water column nutrient concentration and macroalgal growth, even in open. tidally flushed systems. These include studies in open systems in Rhode island, Massachusetts, Western Australia, Italy, and France. In these shallow coastal systems, with sufficient light for algal growth penetrating to the bottom in most areas, macroalgae dominate. Water column nutrient concentration is very dynamic, and very transient. For example, Enferomorpha is able to take up UCLA Biology Department ('=L: 310-206-3987 N(^ 21,95 10:45 No.004 P.04 sufficient nutrients in 1 day to maintain growth for weeks; conversely, it is able to strip nutrients from the water column almost to the limit of detection In a very short time. However, those nutrients are not gone from the system, just sequestered during the bloom. They will be re-released as NH4 or dissolved tri organic nitrogen after the bloom, and may cause significant impacts. I have just returned from an Estuarine Research Federation conference that was focused on estuarine eutrophication. There were 4 days (30 papers per day) of talks on how to best predict eutrophication. Not one scientist suggested using water column nutrient concentration; most advocated total nutrient loading to the system. 4. The authors of the EiR have several comments on my published work. I will only address a few, as most are dealt with in the above discussion. 1) The authors suggest that the fit between water column nutrients and growth is actually better (but non-linear and multivariate) than indicated in my 1994 paper because of temporal variability, i.e., that the fit is not good at the early and late stages of bloom. However, the t thethey refer to has no same point in time foe alloral experimentalexpe�mental nt. In other words, they were taken units. 2) The authors point out that I used a Monad function for macroalgal nutrient uptake, and use this to justify their choice of water column nutrients as a predictor of growth. What they fail to acknowledge is that the primary forcing function was nutrient supply to the system. In addition, I used TWO functions, one for uptake based on water column nutrient concentration, and one for growth based on internal nutrient storage. Water column nutrient concentration was extremely transient (the algae took up up to 40 µM a day), and internal storage was key to causing the algal blooms. Thus, the model that predicted algal growth and biomass accumulation was far from the "classic" formulation used for phytoplankton. 5. The EIR states that an "open" system mimics anatal system dy state. Tha� a s is not sSimteady not true. Freshwater inputs in the wet season in a ea 'ur state, but pulsed. Water flows in response to rain events, which in southern California are discrete pulsed events. Thus, allochthonous nutrient Inputs are also pulsed events, and many of the nutrients are directly flushed to the ocean during floods. In the proposed project, freshwater and nutrients will be supplied at a constant rate over the wet season. This is very different from the natural pattern, and we have insufficient knowledge about how this change In supply rate will affect the algal community. 6. Much of the confusion over this whole issue arises from issues of scale and/or semantics. It is very important to realize that concentration versus loading is a non -Issue; for different systems these predictors have both been useful. In deep water phytoplankton systems, water column concentration has been useful; in shallow coastal systems, nutrient loading has been a better Indicator of impact, but neither are mechanistic. What is really KEY is to Public Works Departr,,,;nt Summary Dr. Peggy Fong, Letter Report Dr. Fong's review of the IRWD Draft EIR for the Wetland Demonstration Project has raised the following questions and concerns regarding the impact of the 5 MGD discharge on algae blooms in the Bay. (1) There is insufficient knowledge of the changes in Nutrient dynamics that will be caused by increased nutrient loading and freshwater input to the Upper Bay to "unambiguously predict" the response of opportunistic green algae that has caused blooms in the past. (2) There is no local evidence to support the "No impact " statement based on reduced water column nutrients. (3) Most scientists advocate using total nutrient loading to the system to analyze potential algae bloom. (4), The EIR statement that "the Bay is an 'open' system which mimics a steady state," is simply not true. Fresh water inputs in wet season under natural conditions are pulsed. (5) Concentration vs. loading is a non issue in this case, and Dr. Fong does not think that nutrient reduction can be predicted with a model that only predicts mixing and flushing of water. (6) There is a need for experimental work in flow-through systems that addresses the question of whether a flow through system in wet season will result in entranced algae production and biomass accumulation. UCLP Biology Department r",EL: 310-206-3987 UNIVERSITY OF CALIFORNIA, LOS ANGELES BERKELEY . DAVIS ' IRVINE - LOS ANGELES ' RIVERSIDE . SAN DiECO - SAN FRANCISCO Dr. Peggy Fong, Assistant Professor Department of Biology University of California Los Angeles Phone: (310) 825-5444 Email: pfong@biology.ucla.edu John Wolter Cooperative Projects Engineer City of Newport Beach Public Works Department P.O. Box 1768 Newport Beach CA 92658-8915 21 November 1996 21,95 10:45 No . 00'4' P . 02 UCLA SANTA BARBARA ' SANTA CRUZ DEPARTMENT OF BIOLOGY 405 HILGARD AVENUE LOS ANGELES, CALIFORNIA 90095-1606 I have read the relevant portions of the proposal to release 5 MGD of freshwater to ponds that will overflow into Upper Newport Bay (UNB), as well as the comments and respadeey oft a M HiE11Rl. 's assessmentAs ,of the potential specifically that these commenting on the quacy actions will stimulate algal blooms. 1. It is my professional opinion that we have insufficient knowledge of the changes in nutrient dynamics that will be caused by the increased nutrient loading and freshwater input to UNB to "unambiguously predict" the response of opportunistic green algae that have caused blooms in the past. The basis of the EIR's claim that they can "unambiguously predict" model impacts lies in the prediction by their model that nutrient concentration in the water column will decrease with increased water inflow. They use a first surder dee tint to describe removal of nitrate from the water column, presumably calibrate model using an existing data base, and then re -run the model with 5 MGD additional water (with the accompanying nutrient load) flowing into UNB. The first order decay coefficient is a single term that encompasses all of the things that remove nitrogen from the water column other than mixing and flushing to the ocean. The nutrient processes that comprise this term include uptake by at least three major functional -forms of algae (macroalgae, phytoplankton, and benthic mats of cyanobacteria) as well as uptake by sediments. As described in the EIR, this term must have been generated by adjusting the parameters of the first order decay function to fit an existing data base of water column nitrogen. A basic assumption of using this technique for predicting future impacts under different water flow scenarios is that the rate of each of the processes that comprise the decay term are constant over time, and that the only component of t UCL.R Diology Department TEL: 310-206-3987 Nov 21,95 10:45 No.004 P.05 understand how algae take up nutrients, and thus are able to grow. To do this you have to know something of the alga's life -history. Enteromorpha, the alga that most often forms nuisance blooms, starts out attached to the benthos in shallow water. At this stage it gets its nutrients from both the benthos (via diffusion of sediment nutrients) and the water column. To be taken up, a molecule of NO3 (or other forms of nitrogen) has to contact the algal thallus. With moving water, the rate that a molecule contacts the surface of the alga is a function of both instantaneous concentration at the surface of the thallus, which changes as different water masses move across, and the amount of water moving past the algae. Thus, the alga may contact the same amount of nutrients with a lower water column concentration, but mere water moving across the surface of the thallus. In other words, increasing net inflow of freshwater in the upper reaches of Newport Bay, regardless of the lowered nutrient concentration (if that actually occurs), may enhance nutrient uptake. Later, when Enteromorpha reaches a critical mass and buoyancy, it detaches and floats, and receives nutrients from the water column only. By this time, it forms floating mats, rafting the nutrients sequestered in tissue down the estuary during the later growth and then decay phase of the algal bloom. If tidal flushing is VERY strong, these rafts may flush to the ocean. However, the morphology of Enteromorpha is such that it is easily entangled around any sort of structure, including salt marsh plants, rocks, pilings, etc. I do not think we can predict removal based on the present model that only predicts the mixing and flushing of water. In conclusion, one obvious result of this whole debate over impacts is that, except for my earlier work in closed systems, there is almost no experimental evidence available about impacts on algae to aid managers in making these difficult decisions. There Is a real need for experimental work in flow-through systems that addresses the question of whether adding a steady supply of freshwater and nutrients during the wet season will result in enhanced algal production and biomass accumulation. In addition, there has been an alternate proposal by IRWD to strip nutrients from the dry season, high nutrient flow in mitigation for the enhanced wet season flow. I do not think anyone would doubt the net benefit of this action. However, there is no information to judge whether a tradeoff (stripping in dry season vs. addition in wet season) will be a net benefit to the system. Again, we need some experiments that focus on these questions and trade-offs before an informed decision can be made. Sincerely r SMC g y Fong M Public Works Department Summary Joy B. Zelder, Ph. D, Letter Report Dr. Zleder's review of the IRWD draft EIR for the Wetland Demonstration Project has raised the following questions and concerns regarding the biological impacts of a 5 MGD discharge to Upper Newport Bay. (1) Average salinity is not the appropriate assessment criterion; (2) a one -dimensioned model is unlikely to provide realistic predictions; (3) the cumulative impacts of altered salinity, altered temperature and altered dissolved oxygen are not addressed; and (4) the EIR does not specify the duration of extreme conditions (e.g. worst - case scenario of an extensive pocket of brackish, warm hypoxic water) or the tolerance of native species to those conditions. While Dr. Zelder cannot say what impact the 5 MGD discharge will produce, she concludes that the project will cause measurable declines in estuarine water salinity, which could stress marine organisms, especially when coupled with warmer temperatures and lower oxygen concentrations. !A- 11/20/95 MON 18:09 FAX 619 5 2035 NBS SAN DIEGO U001 Joy B. Zedler, Ph.D., Wetland Ecologist 5302 E. Palisades Rd. San Diego, CA 92116 John Wolter Cooperative Projects Engineer City of Newport Beach Public Works Dept., PO Box 1768 Newport Beach, CA 92658-8915 Dear Mr. Wolter: I have read relevant portions of the proposal to begin releasing 5 MGD of freshwater to ponds that will overflow into Upper Newport Bay (UNB); I have also read the review of the hydrological model by Water Engineering &Modeling (signed by Bogle). I have the following comments. - The purpose of the project is stated as creating waterfowl ponds. If this is the case, then overflow into UNB is not required. I assume there is an additional purpose of disposing of excess treated wastewater; it should be so stated. Otherwise the proponents need to show why a zero -net -discharge program would not fulfill the objective. - The proposal includes results of a hydrologic model which are interpreted as showing there would be no significant impact on salinity in UNB. I am neither a hydrologist nor a modeler, but a biologist. Hence, my interpretation of the model and its output are couched in biological terms. The model predicts the average salinity that would occur in an unstratified water column (one-dimensional model). This type of model has two shortcomings for assessing impacts on biota. First, the average salinity is not the appropriate indicator of stress to marine and estuarine oroganisms, but the extremes of salt concentration and their duration. Second, the salinity patterns in the estuarine channels are likely to be very complex, with vertical stratification and pockets of water that are above or below average salt concentration. Such is the case for Tijuana Estuary, where a preliminary two- dimensional model has been constructed (Kamman et al. 1995) considering field data on salinity from 12 sampling stations throughout the estuary. This model was 2- dimensional in plan (X and 1), estimating depth -averaged salinities within the estuary. While the 2-D model did not incorporate stratification, it can represent the plan circulation both within the channels and on the inundated marshplain, as well as the flows field and salinity structure asssociated with the wetting and drying of large expanses of marshplain. The 1-D model is not capable of simulating these processes. The more complex, and more realistic, 2-D model shows that pockets of freshwater are trapped in the estuary's channels. It needs to be known whether this is true at Upper Newport Bay, as the salinity effects would be very different from those predicted by a 1-D model. It is important to know how low salinity would become, how long it would stay low, and where these conditions would occur within the estuary, as well as within the water column. I would expect the low -salinity influence to extend further downstream during 11/20/95 MON 18:10 FAX 619_: 2035 NBS SAN DIEGO low tides, although data from Tijuana Estuary indicate that freshwater can move about the estuary as pockets during low and high tide (PERL 1995). Salinity impacts are not likely to act independently on organisms, but rather in concert with temperature and dissolved oxygen concentrations. Marine species, such as California halibut, are negatively affected by low salinities (Baczkowski 1992), warm temperatures, and low dissolved oxygen, although the details of the three-way interaction are untested. Freshwater discharges from waterfowl ponds are likely to alter temperature and dissolved oxgyen in the water. Water flowing through shallow impoundments will usually be warmer than tidal water; hence, it will hold less oxygen. . The tolerance of California halibut, other fishes, and molluscs to lowered salinity has been tested (Baczkowski 1992, PERL, unpub. data), although their ability to survive all possible scenarios of salinity level and duration is not known. From current evidence, we know that all species tested were least stressed under continuous marine conditions. While I cannot say what the impacts of a 5 MGD discharge will be, it is clear that the impacts have not been adequately evaluated, because (1) average salinity is -not -the appropriate assessment criterion; (2) a one-dimensional model is unlikely to provide realistic predictions; (3) the cumulative impacts of altered salinity, altered temperature, and altered dissolved oxygen concentrations are not addressed; and (4) the EIR does not specify the duration of extreme conditions (e.g., a worst-case scenario of an extensive pocket of brackish, warm, hypoxic water) or the tolerances of native species to those conditions. In my professional opinion, the 5 MGD discharge would produce measurable declines in estuarine water salinity, which could stress marine organisms, especially when coupled with warmer temperatures and lower oxygen concentrations. The magnitude of the impact would depend on the organisms that use the habitats where such extremes would develop. • It is critical that the impacts of excess freshwater flow be thoroughly and carefully documented and that deliberate discharges not exacerbate existing hydrological problems in the region's estuaries. There are already impacts of impaired tidal flow, altered circulation, sedimentation, urban runoff, and lowered water quality; it must be certain that additional discharges not result in a cumulative impact that either damages native populations or encourages invasive exotics. It is particularly important to understand the impacts on San Diego Creek, where recent installation of check dams has limited the spatial extent of tidal action. Increasing the freshwater.discharge may compound such impacts. The state of our understanding of freshwater impacts is incomplete, but the nature of the problem is known: (1) Excess freshwater stimulates invasions of natural salt marshes by exotic plants; (2) some exotic fishes, such as sailfin mollies and mosquitofish, are associated with seawater that is measurably diluted; (3) various marine invertebrates and fishes are known to be sensitive to salinity dilution; and (4) California halibut, a target species for coservation efforts at Upper Newport Bay, is sensitive to salinity dilution. Lack of complete understanding is not an excuse to proceed blindly, but a reason to be extra cautious. The burden of proof should be on the discharger. This EIR has not proven its claim of "no impact." y --- Respectfully submitted, Joy Zedler, Ph.D. Wetland Ecologist U002 11/20/95 MON 18:12 FAX 619 594 2035 NBS SAN DIEGO References: Baczkowski, S. L. 1992. The effects of decreased salinity on juvenile California halibut, Paralichthys califomicus. M.S. Thesis. San Diego State University, San Diego. Kamman, R., E. Zedler, P. Goodwin, and R. Sobey. 1995. A preliminary assessment of a salinity model for the Tijuana Estuary. Section H in PERL 1995. PERL 1995. Restoring coastal wetlands. Annual report to the USDI National Biological Service, San Diego Field Station. San Diego. Q003 WA "RECEIVED AFTER PFNDA PRINTED." R. A. Nichols Engineering�Ec6xrNOVn , IQ 2T lyy5 519 Iris Avenue, Corona del Mar, CA 92625 k �mQ«RK '9rIOW�t (714) 644-7735 • Fax (714) 640-7316 Newport Beach City Council November 24,1995 3300 Newport Blvd. Newport Beach, CA Dear Mr. Mayor and Council: Re: Irvine Water District Wetlands Water Supply and San Diego Creek Diversion Project We have read with interest some of the material published in the paper and material that the Irvine Ranch Water District, IRWD, has sent concerned citizens regarding the Wetlands Water Supply Project, i.e."Wetlands Water Supply Project Information", and "Answers to Questions About The Wetlands Water Supply Project". It is our understanding that this project has two parts: First, up to 7.73 cfs of newly generated reclaimed water from population and industrial growth within the district will be cycled through the wetlands marsh ponds before being released into the Bay. Secondly, the San Diego Creek Low Flow Diversion Project is a companion operation to divert up to 10 cbs of high nutrient water from San Diego Creek into the San Joaquin Marsh to clean the water and serve as a summertime water source. T1us proposed reclaimed water use would essentially flow the water into the bay with virtually zero water reclamation. Since there is presently water in the ponds there would be only minor evaporation differences. Underground water replenishment is extremely important. Fresh water available for this purpose and or available to reduce vegetation watering should be used for these purposes. We would note that Water Factory #21, Huntington Beach is using reverse osmosis tertiary treatment and then injecting the water back into the ground to replenish the fresh water underground water supply. Certainly this is very costly 1* if this preserves the water table and helps prevent salt water inclusion it, may be worthwhile to consider. We would note one of the ways Newport Beach is trying to minimize water costs is to pump water from this same water table from Fountain Valley underground wells. We believe at least some of the present IRWD reclaimed water is being used in a separate reclaimed water system for vegetation. For example from "Answers" above for Question #I we read, "This water has been used in the IRWD service area for the last 30 years for landscape irrigation on golf courses, green belts, residential yards, parks and school playgrounds." This use is very desirable in that it usually displaces a like amount of potable water from being used for this purpose and secondly since this water seeps down into the ground it acts to replenish the fresh water aquifers and help lessen salt water inclusion in our underground water supply. We understand that a reasonably extensive Reclaim water distribution system for this purpose is already in place but that the cost of the reclaimed water is so high that even golf courses such as Santa Ana Country Club are hesitant to use the water. We would note that such use on their part requires conversion of a potable water distribution systems and secondary costs of running a second potable water system for drinking fountains, restroorns and such. We would suggest that subsidizing such conversions such that the reclaimed water can be used in these more beneficial ways is more desirable than flowing it to the ocean. R.A. Nichols Engineering Mr. Mayor and Council Newport Beach City Council November 24,1995; Page 2 We would note the IRWD proposes, "Answers" above Question #10, "The San Diego Creek Low Flow Diversion Project is a companion operation to divert up to 10 cbs of high nutrient water into the San Joaquin Marsh to use as a summertime water source. The benefit of this project will be to remove Nitrogen from the water before it is returned to San Diego Creek." Note, 10 cbs is 1.3 times as much water as the reclaim water supply (5,000,000 gal/day = 7.73 cbs). We suggest that the Low Flow Diversion Project makes sense but that the tertiary treated water and maybe even the overflow diverted creek water should be reclaimed for direct reinjection or used for landscape irrigation within the district. Fresh and or reclaimed water is to valuable a resource to flow into the ocean. Our main concerns from a technical standpoint are system Upsets and / or Breakdowns. We work with Hyperion which does primary, secondary, and some tertiary treatment. Tertiary treatment usually involves chlorination and dechlorination, normally with chemicals. Hyperion upsets have injected enough raw sewage into the Ocean, Santa Monica Bay, that all nearby beaches had to be closed. Where do the IRWD upsets go and of what products do they consist? Do these upsets enter San Diego Creek and Newport Bay or they discharged via pipeline to the ocean. How deep and how far out is this outfall. If under such conditions less than tertiary processed water would enter the ponds, would they not be poisoned. How about Newport Bay. How are present upsets handled. This project is obviously a shortcut method of getting rid of reclaimed water. What usual methods are used and/or required? These questions should be openly addressed in these information handouts. These questions should be handled in the EIR and openly discussed as part of this project. Very truly yours, Richard A. Nichols,Ph.D. RAN: sn cc.Irvine Ranch Water District Board,PO 57000, Irvine CA.92619-7000 "RECEIVED AFTER AGENDA RICHARD H. MAZY PRINTED:" 3614 Seabreeze Lane Corona del Mar, California 92625 November 25, 1995 The City Council Newport Beach, California IF I VEKI N10V 27 1995 CITU (If RK CITY OF NRPORT BEACH Dear mayor John; Council -People: Jean, Janice, Norma, Thomas, Dennis and Lame -Duck -John C.C.: I am amazed that our governing officials have not instigated a solution to solve the threatening catastrophe that is about to flood our wonderful Bay! This isn't a matter of "not in MY backyard". Rather, it's a MORE acute demand of "don't pee in MY pond!" We have more than enough sloppy boat owners who think nothing of dumping their body waste in our bay) without adding the effluents of the affluent from Irvine,in these prestine waters. At least, in the "process of elimination" we can eliminate the City of Irvine as a contender for the "Royal Flush". Larry Agrin protected Irvine from the "Greenhouse Affect". Now our City Council must protect us from the "Outhouse Affect". It is strictly up to you, Counull Members, to "pull the chain" on Irvine. If we don't want Bayside Drive to be the "Toilet Seat"of the South Coast, you must act Now! We won't be the "Cesspool on Demand" nor the "Pooper Scooper" for our Inland neighbors. NO extradition for you -know -WHAT! 3:I ur Best Interest, r ./ Richard H. MaZy P.S. If this isn't stopped, now, we'll be taking a daily "Albumin Count", in the Bay, from now on. dd: Calif. Water Quality Control Board J J Y 1, ,,-PULL THE CHAIN I V 11V E1 / ..40VED AFTER AGENDA PRINTED;" Clinton iiyoel 1c07 �a.l a;tca =ci, c Corona del Ivar, CA. 92625 November 24, 1995 le,.,�ort c:.ch City Council / %r4 ,_•, 3300 Idetiroort Blvd i seri¢„! Neiwport reach, CA. 92658 NOV 27 1995 MY ClsRK "1 OF Dear Liayor Hedges and CityCouncilI'iemberss \ r��rC11'r Tncy Each of you rre aware that I am concerned aboiit va-riolrs forms of POLLUTION affecting the City of Nev. ort each. As ,,rou known I am a member of the City-xi.ation CozmrLittee as well as a member of tht )or;xd of A.'4V.G. T ---is letter is from Firs Rygel add q�,,rself as residents of this beautiful city which "ain't uh-.t it used to bell -Vie discovered IQewport in 1950 z,rhen we purchased our first home on the east end of the Peninsula. A year or so later I bought my first sailboat$--- a day-sailerLd have been sailing the Bay and off shore waters -regularly ever since and several boats later. Our :'first mooring can =.s the third can westerly of the end of the pen--i-nsula ch 4ae had for several years. For the past 28 years o* so we have had A Balboa Yacht Club off shore mooring. I KNOW NhMPORT BAY WELL. In the early days I would row out to my mooring ana as I approachea my sailboat I could easily see its deep propeller and keel. We and our three da.iz-'i�.ters ould often s-vrim the relatively clean bay. I EVER , along came several grand children and we asked their paraits to not allow them to swim the Bay because of environmental pollution of various sorts, t'or many years I have not been able to see the Keel or propeller of our vcfxious sailboats. hiven a-ffrer the dredging done aro-und ten ye��_rs w ---o the Bay eras still polluted ai1d. ! kd k;V&ZEe'G_Ja, . ,-rs. 4- —el and I uil, e v-ou tO o T :LLOW the Wetlands Dilater Supply project proposed by the Irvine Vlfater i1 strict to dump treated WASTE vVATrR into Upper Newport Bay. Unquestionally this would cause serious1 _ ;.0 toliNTAL DAMAGE TO OUR BEAUTIFUL ONE OF A KI_,D SAY ON TI1-1-P, Ur1EST CONST. "Otis .say” :ust ,°ece_ve proper environmental _rot. ct:i_on. Plc,, -,se do not allow any additional -oollut nts to enter the Bay. I have reason to be1e e that there is sub surface pollution entering the tray from the JI.W.A. and it is common knowledge that J.'sa.A. causes and allows Jet Aircraft pollutants to dettle upon the Bay. The Bay must be protected from SUB SURFACE, SUAFACE, ,SND .iBOVE SURFACE POLLUTION of all sorts. Beautiful Nei�port ;::each needs protection from environmental pollution of all sorts. The present and future generations are entitled to this kind o_ : rotection and only GOTS :2,NT ACTIOI�,l tr ill .s r.re proper protection. - inton,T� e1 J o City Clerk: lls see that each member of cou--icil is copied. cc: Calif. A'e ,ional Quality Control Ooard, Santa ana ;e ion. N O V- 2 7 -'9 5 MON 1 0: 3 7 W O L F F ENG I N E E R I N G 0 u November 17, 1995 Mr. Robert M. Wolff 611 Gorgonia Newport Beach, CA 92660 R - 02! CITY OF NEWPORT BEACH Subject: IRWD Wetlands Water Supply Project and Upper Newport Bay Dredging dear Mr. Wolff, I have reviewed your letter dated November 13, 1995, with City engineering staff who administer the Upper. Bay Dredging projects. They assure me that the strict environmental regulations which govern dredging and disposal of the dredged material will provide for :protection of the bay during the dredging operations. Bioassays of the dredged material are " required by the U.S. Environmental Protection Agency (BPA) to ensure that the dredged Material meets very strict toxicity standards and is compatible within the ocean disposal site. .Strict standards required by the Regional Water Quality Control Board ensures that turbidity is cOntro'lled: at the dredge. Project specifications require water quality monitoring during the :d`edg n'g operations to ensure that the turbidity requirements are met. Construction of sediment basins in the upper bay have proved very effective in collecting '40diment. which would have otherwise moved into the lower bay during storm flows from the ;fin Diego -.Creek watershed. While the proposed IRWD discharge should not add sediment to the: 7.1.cfs...(5MGD) discharge when, compared to winter storm flows in San Die o 'Greek of Up 46: so -00 cf$; w"iil have a very small'if an beneficial impact on sddimenf assn` Y p ,p. g through the bay, Thank you for your interestin the bay. Your comments have been received by the City :Council and if you have questions or additional comments, please call John Wolter, our project Manager for the Upper Bay Dredging project, at 6443311. Very truly -yours, Kevin 4�urn�hv City Manager ;;J'City. Z- -all • 3300 Newport Boulevard • Newport Beach, California 92663-3884 "RECEIVED AFTER AGENDA PRINTEV' PAUL H. RYCKO]FF 1321 OUTRIGGER DRIVE CORONA DEL MAR, CALIFORNIA 92625 (714) 720-1321 November 27, 1955 l 4yor and Council Members Newport Beach, California I hope the Council Members will unanimously oppose the IRWD Plan to discharge treated sewage into Newport Bay. It is not worth the gamble on the effect on public health of further potential deterioration of Bay water quality resulting from the dumping of millions of gallons of chemicals and sewage into it. Further, the public perception of this tampering with water quality in a public recreation area is bound to be a large negative. The Orange County Sanitation Districts' handling of the effluent is a much more palatable method of disposal. Yours truly, ''RECEIVED A ER AGENDA PRINTED:,' -- November 27, 1995 Deas Mayor Hedges and City Council Members: f;tti t� G KALN , >\ , CY�WJtti Please vote tonight to reject the Irvine Ranch Water District proposal. Thank you. i Sincerely yours, l - L aMti Debby Ann Evans 4018 Channel Place Newpqrt Beach, CA 92663 .'S& V--�, 71-� CO(f) K, I Wr�� poo�,n S e�oc�.r- Q S202-1an n e D 6 at, 9 cua-VV's rL, PETITION IN OPPOSITV^N TO DUMPING 5 MILLION GALLONS PER DAY OF HIGHLY TREATEu SEWAGE WATER INTO NLdPORT HARBOR. We, the undersigned, are opposed to the Wetlands Water Supply Project proposed by IRVINE WATER DISTRICT (IRWD). The project would allow injecting up to 5 MILLION GALLONS PER day of highly treated sewage water into San Diego Creek which feeds Upper and Lower Newport Bays. This project puts the upper Newport Bay Ecological "` Reserve and Newport Harbor at risk. W"C, MED AfTEk A(zUibi All are Invited to sign. PRINTED:" NAME (print) Rinnnhiro Dhn t:.x (A t kb` \A •� rte. -/&AAL NAME (print) Signature ffA� a oveWicyniA► `C.5`zr cs Address rin, e r NAME (print)igna r Nt�°1 n i��vno L� r, -Swami G Address city Phone a54� k Zip 2 oq horde cl 3 l� Zip L "() rl u n 71� h - -Q CI" Cao 9)�3T� � NAME (print) Signature Phone lqf l Fres molc 4 R 371 J Address city Zip /? 0/ p_ /P �L k n f7 NAME (print) Address JV M C Ly i JOU S° NAME (print) 1�_Iq W t QAy 4_\Jr� Address / n �, ) t 2 T e. (y) Cc n n NA (print) Address C-,)3 NAME (print) Address a/T/T Q on NAME (print) 7 f 7__7 111 J,,,P�� NAME (print) Address GiryZip Make as many copies of this petition as you can get signed and return to SPON, P.O. Box 102, Balboa Island, CA 92662 Signature city Signature NewnoR-r )�Cr+49 CA ci ignature Fre-&n Signature h'7 J,(I rv, t , 1;� Signature \Phone qCz Zip ,14) 679 3s63 Phone Rd -6 6/ Zip Phone Zip q�aS�. Phone J'3 o Zip '7/1�- pyo - Y Phone Zip Phone .YOUR PRESENCE .S IMPORTANT- BE DON'T SAY SOMEONE ELSE WILL. IF YOU WON'T HELP EEN & HEARD STOP IT, WHO WILL? MONDAY NOVEMBER 27, 1995, 6:00 PM SHARP. Arrive early & fill out a public comment card. Irvine Ranch Water District (IRWD) board of directors Room. 15600 Sand Canyon Avenue, Irvine Take the 405 South past Jeffrey. Exit Sand Canyon. (past Barranca before Irvine Center) IRWD needs to see faces & hear voices of the adults and CHILDREN who oppose there. ASK OTHERS TO JOIN YOU. WE NEED ATTENDANCE. WE NEED EVERY ONE WHO DOESN'T WANT THE BAY TO BE A SEWAGE OUTFALL THERE. TELL_ IRWD WHAT YOU THINK OF THEIR PLAN. LET THEM KNOW WE WILL FIGHT IT The press & OCN might give us coverage if enough confirm attendance. Call 714- 722-1710 to confirm you will attend. It /S important "RECEIVED AFTER AGECut off here after the November 27th meeting tl- ------------------- AGENDA j"`INTED," ._.,L g PETITION WE OPPOSE DISCHARGING 5 MILLION GALLONS PER DAY OF HIGHLY TREATED SEWAGE INTO NEWPORT HARBOR. We are opposed to IRVINE RANCH WATER DISTRICT (IRWD) discharging 5 MILLION GALLONS PER DAY of highly treated sewage water into San Diego Creek, which feeds Upper and Lower Newport Bay. We believe discharging treated human waste and industrial waste puts the Upper Newport Bay Ecological Reserve and Newport Harbor at unnecessary risk. We call upon our legislators, (city, county, state, & federal) to enact legislation to clearly prohibit the discharge of treated human waste into recreational bays where rowing, canoeing, swimming, and sailing are enjoyed. The Plan has nothing to do with the water crises - It does NOT save water. We encourage strong opposition of IRWD's discharge plan, including litigation if necessary, to protect this critical natural resource, its marine life, and the people who use and enjoy it from such unnecessary risks. After lengthy study this project is opposed by nationally recognized Physicians, Scientists, Educators, Environmentalists, Business Owners and Civic Leaders. Including: Dr. & Mrs. Jack Skinner, SPON, Newport Aquatic Center, Harbor Quality Committee, Bill Bretz -UC Natural Reserve, Dan Marcheano-The Arches Restaurant, council member Norma Glover, Lee Sutherland, Mr.& Mrs.Philip Ramser, Bill Grundie, Arthur Gronsky, Bob Caustin, numerous Community Associations including: Lido Isle, Newport Island, Newport Peninsula, Balboa Island, Harbor Island, and literally thousands of concerned citizens. IRWD HAS IGNORED OUR CONCERNS & IS GOING FORWARD. WE"NEED-YOUR HELP, NOVVTO STOP THEM. NAME (print) Address 5 NAME (print) Address , 7/y-671-7 2CZ Phone i- City Zip FAX # or EMAIL FOR ISSUE UPDATES Signature Phone city Zip FAX # or EMAIL FOR ISSUE UPDATES NAME (print) Signature �� ��—tea �- �• / 0 ► �� Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES Make copies Get them signed HELP IN UP TO FIVE WAYS.. Get them in. Get involved. 1; ""RITE C." THE "RESP & POLITICALLY INVOLVED INDIVIDUALS. 2) GET SIGNATURES. ATTEND, & VOICE YOUR OPINION AT UPCOMING BOARD MEETINGS. 3) HELP Citizens for Sewage Free Bay GIVE OUT FLYERS & ORGANIZE ATTENDANCE. 4) JOIN OR LEAD A COMMITTEE. 5) ASK INDIVIDUALS, BUSINESSES, & CORPORATIONS FOR DONATIONS TO FIGHT IRWD. Distribute copies of this petition and send them to: Citizens for Sewage Free Bay, P. D. Box 170, Balboa Island CA 92662 (714) 722-1710 DEFEND THE BAY WITH YOUR DONATIONS OF TIME & MONEY YOUR PRESENCE :S IMPORTANT- BE EEN & HEARD DON'T SAY SOMEONE ELSE WILL. IF YOU WON'T HELP STOP IT, WHO WILL? MONDAY NOVEMBER 27, 1995, 6:00 PM SHARP. Arrive early & fill out a public comment card. Irvine Ranch Water District (IRWD) board of directors Room. 15600 Sand Canyon Avenue, Irvine Take the 405 South past Jeffrey. Exit Sand Canyon. (past Barranca before Irvine Center) IRWD needs to see faces & hear voices of the adults and CHILDREN who oppose them. ASK OTHERS TO JOIN YOU. WE NEED ATTENDANCE. WE NEED EVERY ONE WHO DOESN'T WANT THE BAY TO BE A SEWAGE OUTFALL THERE. TELL IRWD WHAT YOU THINK OF THEIR PLAN. LET THEM KNOW WE WILL FIGHT IT The press & OCN might give us coverage if enough confirm attendance. Call 714- 722-1710 to confirm you will attend. Cut off here after the November 27th meeting PETITION It /S important WE OPPOSE DISCHARGING 5 MILLION GALLONS PER DAY OF HIGHLY TREATED SEWAGE INTO NEWPORT HARBOR. We are opposed to IRVINE RANCH WATER DISTRICT (IRWD) discharging 5 MILLION GALLONS PER DAY of highly treated sewage water into San Diego Creek, which feeds Upper and Lower Newport Bay. We believe discharging treated human waste and industrial waste puts the Upper Newport Bay Ecological Reserve and Newport Harbor at unnecessary risk. We call upon our legislators, (city, county, state, & federal) to enact legislation to clearly prohibit the discharge of treated human waste into recreational bays where rowing, canoeing, swimming, and sailing are enjoyed. The Plan has nothing to do with the water crises - It does NOT save water. We encourage strong opposition of IRWD's discharge plan, including litigation if necessary, to protect this critical natural resource, its marine life, and the people who use and enjoy it from such unnecessary risks. After lengthy study this project is opposed by nationally recognized Physicians, Scientists, Educators, Environmentalists, Business Owners and Civic Leaders. Including: Dr. & Mrs. Jack Skinner, SPON, Newport Aquatic Center, Harbor Quality Committee, Bill Bretz -UC Natural Reserve, Dan Marcheano-The Arches Restaurant, council member Norma Glover, Lee Sutherland, Mr.& Mrs.Philip Ramser, Bill Grundie, Arthur Gronsky, Bob Caustin, numerous Community Associations including: Lido Isle, Newport Island, Newport Peninsula, Balboa Island, Harbor Island, and literally thousands of concerned citizens. IRWD HAS IGNORED OUR CONCERNS & IS GOING FORWARD. WE NEED YOUR HELP, 1%T0VV. TO STOP THEM. Phone FAX # or EMAIL FOR ISSUE UPDATES 673- Phone FAX # or EMAIL FOR ISSUE UPDATES JA -7 A Z S � 77 Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES Make copies Get them signed HELP IN UP TO FIVE WAYS.. Get them in. Get involved. A) Y!"'ITE ": CALL LEGISLATORS, THE PRESS & POLITICALLY !MVOL VED INDIVIDUALS. 2) GET SIGNATURES. ATTEND, & VOICE YOUR OPINION AT UPCOMING BOARD MEETINGS. 3) HELP Citizens for Sewage Free Bay GIVE OUT FLYERS & ORGANIZE ATTENDANCE. 4) JOIN OR LEAD A COMMITTEE. 5) ASK INDIVIDUALS, BUSINESSES, & CORPORATIONS FOR DONATIONS TO FIGHT IRWD. Distribute copies of this petition and send them to: Citizens for Sewage Free Bay, P.O. Box 170, Ba/boa lsland CA 92662 (794) 722-1710 DEFEND THE BAY WITH YOUR DONATIONS OF TIME & MONEY NAME (print) Signature c Address City Zip Signature NAME (print) 3 -3&a 92 66 Address City Zip NAME (print) /D 6A Signature AddressCity I �l Zip _ G12)(.r ) [dr �Cl 1 S, L� 2. NAME (paint) Signature Address City Zip NAME (pr t) Signature . _ Address-� CityZip Zip ' Phone FAX # or EMAIL FOR ISSUE UPDATES 673- Phone FAX # or EMAIL FOR ISSUE UPDATES JA -7 A Z S � 77 Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES Make copies Get them signed HELP IN UP TO FIVE WAYS.. Get them in. Get involved. A) Y!"'ITE ": CALL LEGISLATORS, THE PRESS & POLITICALLY !MVOL VED INDIVIDUALS. 2) GET SIGNATURES. ATTEND, & VOICE YOUR OPINION AT UPCOMING BOARD MEETINGS. 3) HELP Citizens for Sewage Free Bay GIVE OUT FLYERS & ORGANIZE ATTENDANCE. 4) JOIN OR LEAD A COMMITTEE. 5) ASK INDIVIDUALS, BUSINESSES, & CORPORATIONS FOR DONATIONS TO FIGHT IRWD. Distribute copies of this petition and send them to: Citizens for Sewage Free Bay, P.O. Box 170, Ba/boa lsland CA 92662 (794) 722-1710 DEFEND THE BAY WITH YOUR DONATIONS OF TIME & MONEY YOUR PRESENCE :S IMPORTANT- BE ,EEN & HEARD DON'T SAY SOMEONE ELSE WILL. IF YOU WON'T HELP STOP IT, WHO WILL? MONDAY NOVEMBER 27, 1995, 6:00 PM SHARP. Arrive early & fill out a public comment card. Irvine Ranch Water District (IRWD) board of directors Room. 15600 Sand Canyon Avenue, Irvine Take the 405 South past Jeffrey. Exit Sand Canyon. (past Barranca before Irvine Center) IRWD needs to see faces & hear voices of the adults and CHILDREN who oppose them. ASK OTHERS TO JOIN YOU. WE NEED ATTENDANCE. WE NEED EVERY ONE WHO DOESN'T WANT THE BAY TO BE A SEWAGE OUTFALL THERE. TELL IRWD WHAT YOU THINK OF THEIR PLAN. LET THEM KNOW WE WILL FIGHTIT The press & OCN might give us coverage if enough confirm attendance. Call 714- 722-1710 to confirm you will attend. Cut off here after the November 27th meeting PETITION It IS important WE OPPOSE DISCHARGING 5 MILLION GALLONS PER DAY OF HIGHLY TREATED SEWAGE INTO NEWPORT HARBOR. We are opposed to IRVINE RANCH WATER DISTRICT (IRWD) discharging 5 MILLION GALLONS PER DAY of highly treated sewage water into San Diego Creek, which feeds Upper and Lower Newport Bay. We believe discharging treated human waste and industrial waste puts the Upper Newport Bay Ecological Reserve and Newport Harbor at unnecessary risk. We call upon our legislators, (city, county, state, & federal) to enact legislation to clearly prohibit the discharge of treated human waste into recreational bays where rowing, canoeing, swimming, and sailing are enjoyed. The Plan has nothing to do with the water crises - It does NOT save water. We encourage strong opposition of IRWD's discharge plan, including litigation if necessary, to protect this critical natural resource, its marine life, and the people who use and enjoy it from such unnecessary risks. After lengthy study this project is opposed by nationally recognized Physicians, Scientists, Educators, Environmentalists, Business Owners and Civic Leaders. Including: Dr. & Mrs. Jack Skinner, SPON, Newport Aquatic Center, Harbor Quality Committee, Bill Bretz -UC Natural Reserve, Dan Marcheano-The Arches Restaurant, council member Norma Glover, Lee Sutherland, Mr.& Mrs.Philip Ramser, Bill Grundie, Arthur Grornsky, Bob Caustin, numerous Community As"ciations including: Lido Isle, Newport Island, Newport Peninsula, Balboa Island, Harbor Island, and literally thousands of concerned citizens. IRWD HAS IGNORED OUR CONCERNS & IS GOING %FORWARD. WE NEED YOUR HELP, NOV. TO STOP THEM. UhME (print) Address /� r NAME (print) SiSi nature Phone C,it� �• Zip FAX # or EMAIL FOR ISSUE UPDATES Signature Address City Zip NAME / (print) S'" nature Address city _ C1rV� c". NAME (print) Signature Address City NAME (print) Address 3 Zip Zip a• City Zip cc 411 Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES l,v 7 Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES Make copies Get them signed HELP IN UP TO FIVE WAYS.. Get them in. Get involved. '.) ?!!:!!TE !, CAL"_ LE07-!SLATORS, THE PRESS & POLITICALLY INVOLVED INDIVInUALS. 2) GET SIGNATURES. ATTEND, & VOICE YOUR OPINION AT UPCOMING BOARD MEETINGS. 3) HELP Citizens for Sewage Free Bay GIVE OUT FLYERS & ORGANIZE ATTENDANCE. 4) JOIN OR LEAD A COMMITTEE. 5) ASK INDIVIDUALS, BUSINESSES, & CORPORATIONS FOR DONATIONS TO FIGHT IRWD. Distribute copies of this petition and send them to: Citizens for Sewage Free Bay, P. D. Box 170, Balboa Island CA 92662 (794) 722-9710 DEFEND THE BAY WITH YOUR DONATIONS OF TIME & MONEY YOUD., PRESENCE S IMPORTANT- BE EEN & HEARD DON'T SAY SOMEONE ELSE WILL. IF YOU WON'T HELP STOP IT, WHO WILL? MONDAY NOVEMBER 27, 1995, 6:00 PM SHARP. Arrive early & fill out a public comment card. Irvine Ranch Water District (IRWD) board of directors Room. 15600 Sand Canyon Avenue, Irvine Take the 405 South past Jeffrey. Exit Sand Canyon. (past Barranca before Irvine Center) IRWD needs to see faces & hear voices of the adults and CHILDREN who oppose them. ASK OTHERS TO JOIN YOU. WE NEED ATTENDANCE. WE NEED EVERY ONE WHO DOESN'T WANT THE BAY TO BE A SEWAGE OUTFALL THERE. TELL IRWD WHAT YOU THINK OF THEIR PLAN. LET THEM KNOW WE WILL FIGHT IT The press & OCN might give us coverage if enough confirm attendance. Call 714- 722-1710 to confirm you will attend. Cut off here after the November 27th meeting PETITION It /Simportant WE OPPOSE DISCHARGING 5 MILLION GALLONS PER DAY OF HIGHLY TREATED SEWAGE INTO NEWPORT HARBOR. We are opposed to IRVINE RANCH WATER DISTRICT (IRWD) discharging 5 MILLION GALLONS PER DAY of highly treated sewage water into San Diego Creek, which feeds Upper and Lower Newport Bay. We believe discharging treated human waste and industrial waste puts the Upper Newport Bay Ecological Reserve and Newport Harbor at unnecessary risk. We call upon our legislators, (city, county, state, & federal) to enact legislation to clearly prohibit the discharge of treated human waste into recreational bays where rowing, canoeing, swimming, and sailing are enjoyed. The Plan has nothing to do with the water crises - It does NOT save water. We encourage strong opposition of IRWD's discharge plan, including litigation if necessary, to protect this critical natural resource, its marine life, ,and the people who use and enjoy it from such unnecessary risks. After lengthy study this project is opposed by nationally recognized Physicians, Scientists, Educators, Environmentalists, Business Owners and Civic Leaders. Including: Dr. & Mrs. Jack Skinner, SPON, Newport Aquatic Center, Harbor Quality Committee, Bill Bretz -UC Natural Reserve, Dan Marcheano-The Arches Restaurant, council member Norma Glover, Lee Sutherland, Mr.& Mrs.Philip Ramser, Bill Grundie, Arthur Gronsky, Bob Caustin, numerous Community Associations including: Lido Isle, Newport Island, Newport Peninsula, Balboa Island, Harbor Island, and literally thousands of conr.;emed citizens. IRWD HAS IGNORED OUR CONCERNS & IS GOING FORWARD. WE NEED YOUR HF.'�TOVV. TO STOP THEM. �p �I�ftlb?p NAME (print) SiE re Ph e Address City Zip . _ FAX # or EMAIL FOR ISSUE UPDATES Je'l-MR5. —1 Af, - Y�, d" -,- NAME (print) Signature 6 ;FA -1 --�>d.C--4q gz Address City Zip NAME (print) Address NAME (print) Address NAME (print) Address Signature City up Signature city Zip Signature City tip � 4 3. Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES Phone FAX # or EMAIL FOR ISSUE UPDATES Make copies Get them signed HELP IN UP TO FIVE WAYS.. Get them in. Get involved. 1" `91T` o, C-"'_'_ ! ""ISL^TI PI Z, THE (PRESS & POLITICALLY IPVOLVED INDIVIDUALS. r 2) GET SIGNATURES. ATTEND, & VOICE YOUR OPINION AT UPCOMING BOARD MEETINGS. 3) HELP Citizens for Sewage Free Bay GIVE OUT FLYERS Ili ORGANIZE ATTENDANCE. 4) JOIN OR' LEAD A COMMITTEE. 5) ASK INDIVIDUALS, BUSINESSES, & CORPORATIONS FOR DONATIONS TO FIGHT IRWD. Distribute copies of this petition and send them to: Citizens for Sewage Free Bay, P.O. Box 970, Balboa Island CA 92662 (714) 722-1710 DEFEND THE BAY WITH YOUR DONATIONS OF TIME & MONEY DON'T LET IT HAPPEN. 5 MILL1044 GALLONS PER DAY OF HIGHLY TREATED SEWAGE WILL GO INTO NEWPORT HARBOR DON'T THINK SOMEONE ELSE WILL STOP IT. IF YOU WON'T TAKE THE TIME, WHO WILL? Malte copes -- Cut off here after the November 27th meeting Get them signed Get involved Help to stop it from happening. POSITION POINTS TO CONSIDER: OPINIONS, VOICES, & ATTENDANCE WILL MAKE A DIFFERENCE. If you won't help to stop them, who will? Act now. Get friends, children, & grandchildren involved. You can have a great impact on the press & politicians. Help stop this abuse by a public agency. IRWD directors are elected officials. There is a lack of `independent' studies regarding viruses and infections when recreating in reclaimed water. Contrary to IRWD's position, many do use the bay in the winter. Sailors, UCI & OCC Crew, Newport Aquatic Center, Newport Dunes, merchants, hotels know Newport is a destination resort EVEN IN THE WINTERI Especially from cold climates IRWD's directors authorized literally HUNDREDS OF THOUSANDS OF DOLLARS to consultants to push the project through. Additionally, IRWD has already spent in excess of $700,000 on the construction of this project BEFORE it has been approved. Clearly they expect to strong arm this project through, over the universal objections of the citizens. The plan has nothing to do with the water crises - It does NOT save water. Allowing treated human & industrial waste in Upper Newport Bay Ecological Reserve & Newport Bay is an unnecessary risk. Newport Harbor is a "no discharge' harbor for every other purpose - why is a treated sewage discharge even being considered? There have been no baseline biological studies above the salt dike, according to IRWD's chief biologist on the project. Therefore there is no way to tell if ecological damage is occurring. Even if there are no ecological or health risks pose by the project ( as stated by IRWD) who wants treated sewage in the bay. Legislators & Editor':j need to know your concerns, silence won't stop IRWD. Daily Pilot Letters to the Editor 330 W. Bay Street Costa Mesa, CA 92627 Fax: (714) 646-4170 Reader Hotline/voice mail (714) 642-6086 Short letters may be dictated. Be sure to give your name & number Orange County Register Letters to the Editor P.O. Box 11626 Santa Ana, CA 92711 Fax (714) 565-3657 Opinion Line(714) 953-2256 Short letters may. be dictated. Be sure to give your name & number The Times, Orange County Letters to the Editor 1375 Sunflower Ave Costa Mesa, CA 92626 O.C..Phone (714) 966-5600 O.C. Fax (714) 966-7711 Hard copy needed fax or mail Be sure to include, name & number. One letter can be photo -copied, sent or faxed to the officials & editors you want to hear and consider you. Your letter's address block might look like: Honorable Peter Wilson [(916) 445 2841] Irvine Ranch Water District State Capital Building [Fax (916) 445-4633] ATT: Jim Hyde [Fax (714) 476-11871 Sacramento, CA 95814 15600 Sand Canyon Avenue Irvine CA 92619-7000 Marian Bergeson Supervisor [(714) 834-35501 County of Orange [Fax (714) 834-2670] Calif. Water Quality Control Board 10 Civic Center Plaza, 5th FI. ATT: Regional Board Members P.O. Box 687 C/O Joanne E. Schneider [(909) 782-3287] Santa Ana, CA 92702 2010 Iowa Ave., # 100 [Fax (909) 781-6288] Riverside, CA 92507-2409 Letters to The Editor (See above) RE: IRVINE RANCH WATER DISTRICT (IRWD) "WETLANDS WATER SUPPLY PROJECT (Your opinions, comments, & points.) Signature Printed name, address, phone, & fax #.