HomeMy WebLinkAboutCUP 194A; Aquaculture Systems International; Conditional Use Permit (CUP) (17)July 11,1990
r” Mr. Arthur L Coe -_ Acting Executive Officer
State of California
San Diego Regional Water Quality Control Board
9771 Clairemont Mesa Boulevard, Suite B
San Diego, CA 92124
AGUA HEDIONDA LAGOON - PROPOSED COLIFORM STUDY
Dear Mr. Coe:
The City is in receipt of your June 11, 1990 letter concerning the Regional Board’s proposed action on
the Agua Hedionda Lagoon Coliform Study. This letter solicits comments on the Regional Board’s
proposed study design, and indicates they are considering naming the City of Carlsbad, Encina Water
Pollution Control Facility (WPCF) and the City of Oceanside as responsible parties for implementation of
that study. As a member agency at Encina WPCF, the City was aware of the coliform issue, but this was the first indication that the City was to be named as a responsible party.
Since becoming aware of our potential involvement in the study, staff has attempted to become more
informed of the precise details and potential financial and legal exposure which may accrue to the City. To date, with limited research and expertise, we have determined that the proposed study is estimated
to cost $soO,OOO to $700,000, with no clear understanding of what might be required should the source
of contamination prove to be non-point source discharges.
As a new participant in the study issue, we have not had suffiiient time to assess potential cost or
liabilities, or to develop the expertise to adequately evaluate the varied and contradictory information that
is being generated on this subject. The City would request a delay on any action to allow further time
to evaluate the problem and the proposed study design as it affects the City.
In evaluating this situation, the City of Carlsbad will assume a dual role. Not only are we concerned as
a named patty in the proposed study, but we are also the primary permit authority for Seafarms West
Mariculture. Seafarms West is currently operating under a Conditional Use Permit that has expired. The
City is now reviewing application for renewal. Given potential health hazards and the potential public
expense required to mitigate those hazards, great care will be exercised in review of the permit extension.
In discussing the issue with the Regional Board staff, four key issues were identified:
1. Mitigation of potential health hazards associated with Seafarms West.
2. The cause of pollution of Seafarms West products.
3. Impact of wastewater discharges on shellfish in general and potential mitigation
measures.
4. The nature and extent of pollution to the lagoon and ocean environments from non-point
source discharges and potential mitigation strategies.
2075 Las Palmas Drive Carlsbad, California 92009-4859 (61 9) 438-1 161
Mr. Arthur L Coe
Agua Hedionda Lagoon - Proposed Coliform Study
July 11, 1990 Page: 2
Only Issues 1 and 2 are unique to this particular situation. Non-point source and ocean discharge
impacts on the shellfish environment are general issues common to all ocean dischargers.
Removal of Seafatms West would presumably eliminate the need for our particular agencies to assume
responsibility for development of the science of shellfish contamination. These issues would revert to the
State agencies with the expertise to better explore and evaluate ocean pollution in general and to develop
appropriate regulatory standards and practices.
The issue of non-point source pollution is being adequately addressed by Order 9042, which the Board
will be considering later in their meeting. The City of Carlsbad fully supports these efforts, and hopes to
continue its active protection of our lagoons and the ocean environment.
Prior to initiating massive expenditures related to the state of the art on shellfish contamination, we would
like to thoroughly evaluate the cost benefiis of the Seafarms West operation. What measures are required
to decontaminate the shellfish to meet heath standards? What are the costs of those measures? How
do the cost benefits of the Seafms West operation relate to the cost of the proposed studies and
potential mitigation measures?
In our zeal to increase our knowledge of shellfish contamination in general, we should not lose sight of
the fact that we are dealing with a discreet health hazard at an individual business. No major expenditure
of public funds should be provided to support any business without a thorough understanding of the cost
benefiis of those expenditures.
I would request that this letter be entered into the record of the July 16 hearing, and that the City of
Carlsbad be given an opportunity to give testimony at the hearing.
Thank you for your consideration.
Cordially, n
LBH:rZ
C: City Manager
Assistant City Manager
City Attorney
Community Devdopmmt Director
Utilities and Maintenance Director
Assistant City Engineer
R.J. Greaney - Carlsbad Municipal Water District
R.W. Graff - Encina
Planning Direct