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:"
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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
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.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
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NAME (print)
Address ,
7/y-671-7 2CZ
Phone
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City Zip FAX # or EMAIL FOR ISSUE UPDATES
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city Zip FAX # or EMAIL FOR ISSUE UPDATES
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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
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City Zip
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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
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FAX # or EMAIL FOR ISSUE UPDATES
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FAX # or EMAIL FOR ISSUE UPDATES
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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 #.