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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