Final
Environmental Statement
OCEAN OUTFALL EXTENSION PROJECT
(WPC-CAL-468)
Carmel Sanitary District
Carmel, California
prepared by
Environmental Protection Agency
Region IX
100 California Street
San Francisco, California
and
California State Water Resources Control Board
1416 Ninth Street
Sacramento, California
March, 1972
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TABLE OF CONTENTS
Page
Summary of Environmental Impact
Statement 1
Background and Description of the Project 2
Probable Impact of the Project on the
Environment 5
Probable Adverse Effects Which Cannot
be Avoided 10
Alternatives to the Proposed Action 11
Short-Term Use vs. Long-Term Productivity 13
Irreversible and Irretrievable Commitments
of Resources 13
Local Objections to the Project 14
List of References 17
Appendix A: Receiving Water Monitoring
Program for Carmel Bay
Appendix B: Comments Received on the
Draft EIS ,
Appendix C: Response to Comments not Covered
in the Text of the Statement
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Type of Statement;
Responsible Federal Agency:
Type of Action;
Description of Action;
Summary of Impact and
Effects:
Alternatives Considered;
SUMMARY
Final
: Environmental Protection Agency,
Region IX
Administrative
Carmel Sanitary District is
constructing an ocean outfall
sewer extension in Carmel Bay off
the central coast of California in
Monterey County. The project is
an interim measure to relieve
existing pollution problems and
is in part being funded by the
Environmental Protection Agency
Federal Grant funds (Section 8,
P. L. 84-660 et seq.).
The principal environmental impact
will be to lower existing conditions
of pollution near the shore line
in Carmel Bay. The principal
adverse effect will be the
existence of a waste water discharge
in an area that is included in a
proposed enlargement of the
Pt. Lobos Underwater Reserve of
the California State Park system.
Other alternatives considered were
a longer outfall sewer extending
seaward beyond Carmel Bay, land
disposal by irrigation and by
evaporation-percolation ponds.
Additional long-range alternate
solutions are currently under study
by a regional water quality planning
agency with State and Federal
financial support.
The draft statement was made avail-
able to the CEQ and the public on
September 13, 1971. This Final
Statement was made available to
the CEQ and the public on March 1,
1972.
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Section 102 (2)(C) of the National Environmental Policy Act
requires Federal agencies to prepare detailed environomental
statements on major Federal actions significantly affecting
the quality of the human environment. The Environmental
Protection Agency, Region IX, under Section 8 of the Federal
Water Pollution Control Act, as amended, has offered Federal
grant funds to the Carmel Sanitary District to assist in the
construction of this project.
The California Environmental Quality Act of 1970 assigns
similar responsibilities to State agencies. Since State funds
have also been requested to support this project, the
California State Water Resources Control Board has participated
in the preparation of this joint statement.
An impact statement should assess in detail the potential environ-
mental impact of the action proposed. Comments on the adequacy
of the assessment contained in the draft statement were solic-
ited from Federal, State, and local agencies; and interested
private organizations and individuals.
The final statements and comments have been submitted to the
Council on Environmental Quality and will be the basis for
future State and Federal actions with respect to this project.
Background and Description of the Project
Waste water collection from the area in and around the City of
Carmel, California, is provided by the Carmel Sanitary District.
The District has also begun to provide service under a recent
agreement to the Pebble Beach Sanitary District located north
of Carmel. The collected sanitary waste waters (the service
area has a separate storm drainage system) are conveyed to
a treatment plant located on the Carmel River about a half-
mile from the Carmel Bay shore where the Carmel River State
Beach, administered by the California Department of Parks and
Recreation, is located (see Figure 1). The present waste water
flow of 1.5 m.g.d. (million gallons per day) is currently
given primary (sedimentation) treatment. A portion of the flow
is percolated through sand beds, collected from the sand beds
by underdrains, mixed with the remainder of the primary
effluent, and discharged to Carmel Bay. It is discharged
through a 14-inch cast-iron pipe which terminates approximately
200 feet from the shore at one foot below mean lower low water
in a rocky area between beaches.
For disinfection, chlorine is applied to the waste water just
prior to its entering the outfall line, which has been in
use since 1951. In 1947 the District began applying some
primary effluent to nearby agricultural lands. It currently
disposes of approximately 400,000 gallons per day in this
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manner during the six-month irrigation season. Sludge from
the treatment plant is dried and used as a soil conditioner.
In the future, if all of the sludge cannot be disposed of in
this manner, some other land based disposal method will be
found. In no case will any sludge be discharged to the ocean.
These treatment and disposal systems have been proven ineffec-
tive in the past in preventing both bacteriological contamination
of offshore waters and effects adverse to the marine biota
in the vicinity of the point of discharge. Following a period
of excessive bacterial contamination in 1969, the nearby beaches
were closed to swimming by the Monterey County Health Depart-
ment. In addition to high bacterial densities, the close
proximity of the waste discharge to the beach areas made the
use of these beaches hazardous, since a relatively low amount
of dilution of the waste by sea water is provided by virtue
of the method and location of the waste discharge.(30)*
The Regional Water Quality Control Board issued a cease and
desist order to the District in December of 1969. As an
immediate corrective action the District began adding much
higher dosages of chlorine. Using this method, the District's
effluent ceased contributing to the bacterial pollution of
the receiving waters of Carmel Bay.
Studies carried out at the Hopkins Marine Station in the
spring of 1970 (33) (45) showed damage to marine plants and
animals in the immediate vicinity of the discharge point.
Laboratory studies also showed both heavily chlorinated and
unchlorinated sewage to be lethal to intertidal animals. A
decrease in photosynthetic activity of various seaweeds was
observed in the laboratory and was attributed to residual
chlorine levels. A major kelp bed plant (Macrocystis) was
found to be particularly susceptible to chlorine damage.
In order to eliminate these adverse pollutional effects, the
District adopted a Master Plan in April 1968 to increase the
level of waste water treatment using the activated sludge
(secondary) process and to extend its ocean outfall farther
from shore into deeper waters where improved dispersion and
dilution would be achieved. This environmental impact state-
ment is directed to the ocean outfall extension project.
The proposed outfall construction is an extension of 895 feet of
24-inch pipe (see Figure 1). Approximately the last 100
feet will be a diffuser section containing ten 4-inch diameter
ports. The outfall pipe will be a cement-mortar lined and
coated steel cylinder. The outfall pipe will be buried and
encased with a minimum cover of 1 and 1/2 feet of concrete.
Numbers in parentheses refer to List of References.
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The new outfall line will tie into the existing outfall at a
point 330 feet landward from the mean sea level line. Thus,
the outfall line will extend approximately 600 feet from the
high water line and 400 feet from the low water line and will
discharge in a depth of 40 to 45 feet of water. The diffuser
nozzles will project 3 feet above the top of the pipe and
end in 90° elbows. The effluent will discharge horizontally.
In March 1969, the District applied to the California State
Water Resources Control Board for a Federal construction grant
under Section 8, P.L. 84-660, as amended. The State Board
approved the project and certified the application to the
Environmental Protection Agency in May, 1970. The District
also applied to the Corps of Engineers for a permit to construct
the project in navigable waters. In accordance with Section
21b of the Federal Water Pollution Control Act, the State
Water Resources Control Board certified to the Corps of Engineers
that there was reasonable assurance that the waste water
discharge would comply with State/Federal water quality
standards. The Corps of Engineers permit was granted subject
to the condition imposed by the Environmental Protection Agency
that only waste waters having received secondary treatment
would be conveyed through the outfall extension.
The effluent from the new secondary treatment faciltiies now
under construction will be discharged through the extended
outfall. Listed below are the characteristics of the effluent
presently being discharged through the existing nearshore out-
fall and the design characteristics expected for the new
treatment process (as supplied by the District). •
Characteristic Units Existing Projected
Flow 1971 MGD 1.5 1.5
1985 MGD - 3.0
Biochemical Oxygen Demand mg/1 188 L 20
Suspended Solids mg/1 42 L 20
Settleable Solids ml/1 0.2 4. 0.1
NBAS (detergents) mg/1 6.3 ^ 2
Grease mg/1 22 L 20
Pesticides & insecticides
DDT, Chlorodane, Endrin, ODD, DDE, Heptachlor, Heptachlorepoxide,
Aldrin, Lindane, Dieldrin (each)
mg/1 £0.02 0.02
Mercury mg/1 0.0006 0.0006
Cadmium mg/1 £0.05 0.05
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The Environmental Protection Agency made an offer of Federal
grant funds to the District in October, 1970. As a required
condition for the grant offer the District agreed to initiate
a comprehensive program acceptable to the State for monitoring
the quality of the receiving waters of Carmel Bay to detect
any damage that might occur to the marine environment. (See
Appendix A) This monitoring program is currently being studied
by the State Water Resources Control Board, in cooperation with
the State Department of Fish and Game and the State Department
of Parks and Recreation, and may be revised to provide a better
understanding of the environmental effects of the outfall. The
District agreed that it would, by February 1, 1974, make one
or more of the following additional improvements if these were
found necessary by the State and Federal pollution control agencies
as a result of the monitoring program:
(1) Extend the outfall,
(2) Increase the degree of treatment,
(3) Implement an alternate method of discharge or
waste water reclamation.
The California Department of Parks and Recreation, in granting
a temporary use permit to the.District for construction of
the outfall across Carmel State Beach Park lands, stipulated
that the installation was to represent a short term solution
to a very critical problem and that the ultimate long term
solution will be the complete discontinuance of discharging
effluent into Carmel Bay.
Thus, this project is recognized by the District as an interim
solution to an immediate pollution problem. Additional
measures will be taken as found necessary to protect the marine
environment.
In April, 1971, the District authorized the award of a
construction contract of $408,400, for extension of the
present outfall. Completion of construction is expected in
January, 1972.
Because of the controversy that has developed surrounding this
project, the Region IX office of the Environmental Protection
Agency has suspended further Federal action relating to this
project pending the preparation and review of this environmental
impact statement. Until this has been completed and a decision
has been reached, payment of Federal grant funds will be with-
held from the project.
Probable Impact of the Project on the Environment
The principal environmental concern related to this project
is its impact upon the aquatic environment of Carmel Bay.
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Carmel Bay lies between the Monterey Peninsula on the north
and Point Lobos approximately 3 miles to the south. It is a
little over one mile wide in an east-west direction. The
bay shoreline contains a mixture of broad, clean sandy beaches,
rocky headlands, and bluffs providing magnificent marine
vistas and water-oriented recreation. The southern end of
the Bay is formed by Point Lobos, the location of Point Lobos
State Reserve which the National Park Service has designated
a registered national landmark (see Figure 2). In addition
to the lands of the Point Lobos Peninsula, the reserve includes
750 acres of surrounding submerged land which formed the first
underwater reserve in the Nation. These waters were designated
as a reserve because of their wide variety of flora and fauna
(10), unusual topography, outstanding natural beauty, and
favorable diving conditions. The underwater reserve is
presently used for education, scientific research, underwater
photography, exploration, spearfishing, and general recreational
diving. It is an outstanding area for skin-diving, as marine
biota can be viewed and studied in an undisturbed natural
environment. There are two species of sea lions that inhabit
the waters surrounding Point Lobos. It is the northernmost
breeding place for the California Brown Pelican and the home
of the California Sea Otter. The California State Department
of Parks and Recreation, which administers this reserve has
proposed to extend the underwater park limits to include all
of Carmel Bay (see Figures 2 and 3).
The California Regional Water Quality Control Board, Central
Coastal Region, has recognized the following beneficial
water uses of Carmel Bay as requiring protection: scenic
attractions and esthetic enjoyment, the marine habitat for
sustenance and propagation of fish, aquatic and wildlife,
fishing, industrial water supply, boating, shipping, and
navigation, scientific study, and general beach recreation
including swimming and other water-contact activities. State/
Federal water quality standards have been adopted in accordance
with the Water Quality Act of 1965. These standards were
selected to provide.adequate protection to the recognized
beneficial uses of the waters of Carmel Bay (9).
The Environmental impact of this project will be felt princi-
pally at the present discharge point, in areas along the
route of the new outfall line, at the proposed discharge
point, and possibly in the Bay as a whole. At the present
discharge point the existing biological damage, health hazard,
and unesthetic condition can be essentially eliminated. The
beaches can be allowed to remain open with confidence in the
increased reliability of contamination control provided by
the project. Full usage of this presently fouled area could
be restored. Any slightly abnormal Bay water salinity and
temperature conditions, at the present outfall location,
created by the present discharge would be eliminated.
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Biological damage can be expected along the route of the
outfall line during its construction. In order to anchor
the pipe and to provide protection from storms and sand
movement, it will be placed in a trench cut into the rock
beneath the beach sand, into the exposed rock in the intertidal
and shallow subtidal zones and into the sea floor. The sea
floor is predominately sandy for a few hundred feet and then
rocky for the remainder of the route. The proposed trench
will be approximately 5 feet wide and 5 feet deep. The entire
length of the outfall pipe, with the exception of the upper
portion of the diffuser nozzles, will be covered with a
minimum of 18 inches of concrete.
The major consequence of the outfall construction will be
temporary removal of plant and animal life in the path of
the trench excavation. Several species of algae cling to
any available rock surfaces. The most important of these
are found in water depths of over 15 feet and include some
Pterygophora sp., Nereocystis sp., and Macrocystis sp.
Pterygophora sp. include a large brown kelp which provides
a habitat for a variety of benthic invertebrates such as
chiton, snails, and anemones; some Nereocystis sp., the bull
or bulb kelp and some Macrocystis sp., the giant kelp, provide
habitat for a variety of fauna ranging from benthic and
neritic organisms to sea mammals. Most of these algae are
annual plants and, therefore, should repopulate the damaged
areas within a few years. The kelp may be expected to gain
a footing on the concrete covering as it did on the rocks.
Excess spoil material from the outfall pipe trench will be
disposed of along the sides of the trench and is expected to
be dissipated by currents in a short time. Over a period
of a few years, as a result of the deposit of rocks and
sand, a substrate comparable to that originally present should
exist.
One other possible consequence of the construction is damage
to portions of the Carmel Canyon wall as the result of blasting
the outfall trench The nearly vertical walls, which in some
places overhang, are cut into jointed granodiorite. They may
be subject to crumbling under excessive stresses. Blasting
will be controlled so as to meet the requirements of the
Department of Fish and Game. The permit from Fish and Game
requires a warden to be on site at all times when blasting is
done. Blasting will also be minimized to avoid damage to the
trestle to be used in laying the outfall pipe.
At the proposed point of discharge of the treated effluent,
the diffuser section will lie in the center of a kelp bed at
a depth of about 45 feet. Initial dilution will be provided by
the jet action of the port. This dilution continues as the
jet stream widens during its rise toward the surface.
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Computer modeling techniques were applied under two sets of
conditions to approximately determine the vertical movement
and initial dilution of the waste water following discharge
to the Bay. Under March conditions, (assuming a
homogenous water column at a temperature of 10.5°C) the
waste plume would reach the surface after being diluted 87 to
1. Under average conditions for Carmel Bay, based upon four
years of observations in Monterey Bay (assuming a linear
density gradient with temperatures of 12.0°C at the surface
and 11.2°C at a depth of 35 feet) the waste plume would
surface after being diluted 78 to 1.
Several studies have been performed in attempts to determine
the current patterns in Carmel Bay. Individual measurements
have shown currents moving in many different directions, but
not enough data is available to fully characterize the complex
circulation patterns in the Bay. Therefore, it must be assumed
that during part of the year, currents will carry the waste
plume to the beaches of Carmel Bay. To determine what effect
this ocurrence will have on water quality, a computer modeling
study was performed for Kennedy Engineers to estimate the
resulting coliform counts on the beaches. The computer modeling
results given here assumes a flow rate of 1.50 mgd (the present
flow) and an initial effluent coliform count of 10,000/lOOml.
If onshore currents 0.10 feet per second carry the waste
plume directly back to shore, the coliform count at the beach,
considering die away, will be approximately 38/100ml. If
currents carry the waste plume directly onto the Point Lobos
shoreline at 0.10 feet per second, the coliform count at
the beach will be approximately 0.06/100ml. The water quality
standard established by the California Department of Public
Health for water contact sports is a maximum coliform count
of 1000/lOOml. The effluent, under March conditions, would
be diluted approximately 400 to 1 if it was carried directly
on shore, and approximately 2000 to 1 at the Point Lobos
shoreline. Under average conditions in the Bay, the dilution
would be approximately the same as the March figures.
Thus, there should be little impact on the Point Lobos State
Reserve. Bacterial densities in the Bay and at the shoreline
should be readily controlled with far lower chlorine dosages
than are presently used because of the improved quality of
effluent and the high degree of dispersion and dilution possible
at the new discharge location.
Among the many forms of marine life presently found in the
vicinity of the proposed discharge, probably the most
significant one is the giant kelp (Macrocystis perifera). This
large species of alga provides a forest within which the sea
otter spends much of its time. It also gives shelter to a
large number of fishes and is the substrate for many of the
marine invertebrates which compose the middle links of the food
chain.
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Much research effort has been expended in the past to determine
whether the marine discharge of domestic waste waters has any
effect upon this species of kelp (4, 11, 24, 35, 36, 38, 45,
57). These studies have been under way since the early 1950's
and seem to indicate that, in southern California at least,
there could be damage occurring to the kelp and to some of
the invertebrates due to the discharge of a mixture of
municipal and industrial wastes following primary treatment.
It is questionable, however, whether these findings could be
transferred from an area of high population density and
industrial development to the colder waters of Carmel Bay which
will be receiving smaller quantities of more highly treated
effluent composed principally of domestic waste waters.
The apparent principal cause for the observed damage to the
southern kelp beds appears to be grazing by three different
species of sea urchins; at least one of which may be stimulated
in its growth and reproductive activities by the particulate
matter in the waste. Such assistance to the life cycle of
the sea urchins results in larger numbers which, in turn,
over-graze the kelp. In Carmel Bay there is a herd of about
145 sea otters which actively feed on some major invertebrates.
The order of preference would appear to be: sea urchins,
abalone, mussels, starfish, crabs, and snails. As a result
the numbers of sea urchins in the area have remained quite
low. It is even possible that nutrient stimulation leading to
an increased sea urchin population might be an advantage to the
sea otters. There also seems to be a geographical distribution
difference, wherein the sea urchin population north of Point
Conception, including Carmel Bay, is smaller and of a slightly
different species composition.
There are other municipal waste discharges in existence which
terminate within kelp beds off the coast of California. Two
examples are the waste discharges of the cities of Santa
Barbara and Santa Cruz (11). Both have terminated in these
locations for over twenty years, and during that period, raw,
partially treated and chlorinated effluents and digested
sludges have, at various times, been discharged with no
apparent obvious detrimental effects on the kelp beds.
Unfortunately, no detailed studies have been made at these
locations to determine the precise effects of these waste
discharges on the entire biotic community.
There is some indication that particulate matter carried by
sewage effluents and, perhaps, other constituents of waste
waters can, under certain conditions, smother the gametes or
other microscopic products of marine plant reproduction and
inhibit algal growth and reproduction. Also, the reduction of
light penetration due to the turbidity caused by poorly treated
waste water effluents could further contribute to the inhibition
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of marine plant growth. Because of the degree of treatment
to be provided, the nature of the waste waters, and the
dilution and dispersion that should be achieved by this
project, it is not believed that these effects will be
significant in Carmel Bay as a result of the proposed discharge.
Thus, on the basis of what is known today, it can be concluded
that some damage to the marine environment will be detectable
in the vicinity of the outfall diffuser as a result of the
discharge. This damage is not expected to be serious, but no
judgment can be made until the information produced by the
monitoring program is complete.
Considering Carmel Bay as a whole, the discharge of more highly
treated and less heavily chlorinated waste waters in a manner
designed to achieve better dilution and more rapid dispersion,
could be expected to have a beneficial effect on the Bay as
compared to its present condition. Reduced amounts of
pollutants such as bacteria, low-grade toxicants, suspended
solids, and chlorine will be discharged to the Bay. Concentrat-
ions of these pollutants in the receiving waters will be
further lowered through dilution and dispersion as compared
to present conditions.
Probable Adverse Effects Which Cannot Be Avoided
Damage to marine life that would occur during the construction
of the outfall line, as previously described, represents an
adverse effect which cannot be avoided by the project. This
damage is expected to be short-lived, and substantially
complete recovery should occur within a reasonably short time
(11, 21, 24, 57).
Some, as yet undetermined amount, of damage will occur as a
result of the treated waste discharge itself. The State Depart-
ment of Fish and Game has stated that "We believe that this
delicate marine community, which is dependent on a well-buffered
marine environment, may not withstand the lowered salinities,
chlorine, herbicides, and other unidentified constituents
associated with secondary treated domestic wastes." (See
Appendix B) The monitoring program should provide a realistic
estimate of the extent of this damage.
The creation of a waste plume approximately 100 feet long on
its main axis would represent an undesirable adverse esthetic
effect. This would be true even though, as expected, the
plume would not be readily recognized. Knowledge of its
presence would reduce the esthetic attractiveness of this area
to skin divers and boaters who are aware of its existence.
The presence of an unnatural influence upon the Bay such as
this waste water effluent discharge would impair the value of
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this particular location as a scientific laboratory for the
study of natural phenomena. /While existing development around
the watershed which drains to the Bay already precludes the
preservation of completely natural conditions, the presence
of this waste water discharge causes a further departure from
the desired natural condition in the isolated area of the
waste discharge.
Alternatives to the Proposed Action
To take no action to correct the existing condition of
bacterial contamination and pollution would be an unacceptable
course of action and is not considered as an alternative
that should be evaluated further. Other alternatives exist,
and they should be segregated into categories of short-range
or long-range alternatives. Since the project which is being
discussed in this statement must be considered a short-term
interim solution, it should be compared to appropriate short-
range alternatives. All long-range alternatives for disposal
of waste waters from the Carmel Valley and adjacent areas will
be studied as part of a recently initiated program to develop
a comprehensive water quality management plan for the central
coastal drainage basins. This study, having an estimated
total cost of $868,000, has been undertaken by the Association
of Monterey Bay Area Governments, with both State and Federal
financial support. It is scheduled for completion within two
years. If found acceptable by the State and Federal governments,
the plan which is developed will be adopted as the officially
recognized plan upon which all subsequent State and Federal
pollution control actions will be based.
Two methods of land disposal of treated waste waters have
been investigated by the District. Some treated waste water
is presently being used to irrigate a 130-acre artichoke field
near the treatment plant site. Under current cropping
conditions, it is possible to dispose of only a fraction of the
present annual flow by this method. The District investigated
the use of this and adjacent land under changed cropping patterns
which would maximize the amount of waste water that could be
successfully applied. It found that all of the present flow
could be applied during the six-month irrigation season if the
entire 220 acres of agricultural land available were used for
this purpose. All of the flow during the wet weather months
would still have to be discharged to the ocean as would future
dry weather flows in excess of 1.7 m.g.d. Since the current
discharge location is unsatisfactory, an extension of the
outfall would still be necessary if this alternate were selected.
The same agricultural land was considered for use for ponding
and disposal by percolation, but seepage from these ponds
would enter the Carmel River. This would lead to accelerated
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eutrophication of the Carmel River Lagoon located at the river
mouth as was experienced about 20 years ago when this disposal
method was employed. Disposal to the ponds would have to be
preceded by nutrient-removal treatment processes to prevent
these undesirable conditions from developing in the Carmel
River Lagoon.
In either of the above land-disposal alternatives the costs
of implementation would exceed $3 million, the approximate
cost of the land. This was considered too great an invest-
ment to make prior to completion of a study of all long-range
solutions, which, it is hoped, would provide more acceptable
and more beneficial waste water reclamation and possible reuse
options.
The alternative of not extending the outfall and discharging
sewage with secondary treatment at the present outfall site
was considered. This alternative was dismissed for the
following reasons: 1) In order to meet water quality standards,
a waste discharge to shallow water would require much higher
degrees of chlorination than a discharge to deeper waters.
It was determined that the resulting chlorination would be more
damaging to the marine environment than would the construction
of an outfall extension to deeper water. 2) Although the
surf zone would thoroughly mix the effluent, very little
dilution would take place compared to an outfall in deeper
water. 3) Discharging to deeper water provides a factor of
safety in the event of plant operation disruptions. 4) The
County and State Departments of Public Health found the present
outfall site to be unacceptable.
Alternatives for an outfall of medium length located elsewhere
in the Bay, were also considered. However, moving the pipe
from its proposed location would increase the costs, and
maintaining water quality in other parts of the Bay would
probably introduce the same problems as the proposed location.
A longer outfall that would take the effluent to deeper water
and provide even greater dilution and dispersion was considered.
However, the construction costs rapidly became very expensive
for extension beyond the proposed disposal point due to the
changing nature of the bottom. Beyond this point the bottom
is made up of shifting sands which would require extremely
expensive anchoring to insure the stability of the outfall. The
cost of an outfall extending seaward, beyond the limits of
Carmel Bay, is estimated to be approximately $6 million. This
alternative obviously would not eliminate the waste water from
the aquatic environment and because of the great cost involved
should be considered only as a permanent disposal method. Such
a commitment would be undesirable at this time and this
alternative, therefore, was rejected although not precluded
from later consideration.
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Other long-range alternatives that should be considered include
consolidation with waste waters generated in the Monterey
area in a regional plan for treatment, reclamation, and reuse.
These alternatives may include application to land in the
Carmel Valley to replenish falling groundwater tables. Land
disposal sites in even more remote locations, together with
wet weather storage facilities, should also be considered.
Advanced waste treatment of consolidated wastes from the
Monterey-Carmel areas should also be considered, if direct
reuse for industrial or other purposes can be shown to be
feasible and acceptable.
Short-Term Use vs. Long-Term Productivity
The short-term usage of Carmel Bay for discharge and assimila-
tion of treated waste water effluent is not expected to affect
the long-term productivity of the Bay (3, 4, 8, 41, 44, 49,
52, 53). While no significant adverse effects are expected, a
comprehensive receiving water monitoring program will be
carried out. Should the findings of this program indicate
that detectable damage is occurring, a more appropriate long-
term solution would be developed and employed without delay.
Upon discontinuance of the use of the extended outfall, what-
ever damage may have occurred would not be expected to have
permanent lasting effect on long-term productivity. It should
be possible to detect undesirable changes in the aquatic
environment before they become significant and before they
become permanent. The marine environment should in this case
quickly recover and replenish itself when the damage-causing
action is terminated.
During planning studies of long-term solutions, consideration
may be given to the use of the proposed outfall extension as
part of a long-term solution, such as for emergency discharges
or for use during wet weather periods. Any such decision
would have to be based on a finding of the monitoring program
that no significant effects, either short-term or projected
long-term, would be expected from such use.
Irreversible and Irretrievable Commitments of Resources
No irreversible or irretrievable commitments of resources have
been identified.
The outfall is planned to be used for an interim period. If
it is discontinued natural conditions should be restored in
a relatively short period of time. No decision on any long-
term use would be made without an adequate demonstration that
the aquatic resources are unaffected.
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The outfall pipe trench, being 5 feet wide and 600 feet long,
would represent a commitment of at least 3,000 square feet of
bottom to this purpose. However, this is not considered an
irreversible commitment, since a relative quick recovery and
re-establishment of near natural conditions should occur once
the construction of the line has been completed.
Local Objections to the Project
There have been a number of local objections to the ocean
outfall extension project, which represents the primary
reasons for preparation of this environmental impact statement.
The principal objections are listed below together with a
description of attempts that were made (if any) to resolve
them.
An early objection to the outfall project was that, as
originally planned, it would discharge the poor quality
effluent currently being produced by the existing primary
(sedimentation) treatment plant. This objection may have
contributed to the defeat of the first initiative place on
the ballot by the District to authorize the sale of bonds to
raise revenues for sewerage improvements. The District
subsequently revised its plan to add secondary treatment to
the existing treatment plant under a separate project. A
subsequent bond issue passed with an 88 per cent "yes" vote.
Objections were raised that the proposal to extend the outfall
for discharge of secondary effluent would cause damage to a
shoreline property owner. A lawsuit was filed requesting a
preliminary injunction against the outfall project. This
suit was dismissed for lack of evidence that the project would
have a detrimental effect on the plaintiff's property.
Objections were raised on the basis that the discharge of
secondary effluent through the extended outfall would cause
damage to the marine resources of Carmel Bay. To allay these
fears, the District agreed to carry out a comprehensive
monitoring program satisfactory to the State that would be
designed to detect any damage that might occur. The District
further agreed that if this monitoring program were to reveal
that any damage was taking place, or was likely to take place,
it would take appropriate action by February 1, 1974, to
eliminate the adverse conditions found. Such action would
include one or a combination of the following actions:
extension of the outfall, upgrading of treatment beyond
secondary, and implementation of an alternative discharge
location, or waste water reclamation.
- 14 -
-------
Some District residents proposed that a nearby artichoke field
be used as a land disposal site so as to prevent any discharge
to the Bay and eliminate the possibility of damage to its
marine resources. They apparently believed that this would
also serve the purpose of keeping this land in an undeveloped
state and would block proposed plans for development which
they found objectionable. The District conducted a study of
this alternative and found it to be deficient, since the
land available was inadequate in size to accept all of the
effluent presently being discharged. As a result, a discharge
to the Bay would be required for the excess dry weather flow
and for all of the flow during wet weather, and an outfall
extension would still be required.
Objections were raised that the proposed project would
permit the District to dispose of a greater quantity of
sewage because of the increased capacity of the outfall line
and thus would encourage population growth and development
in the surrounding area. No resolution to this objection was
attempted by the District, since it is not within its province
to control development by purposeful underdesign of sewerage
facilities.
Objections were raised that the District should examine more
alternatives 'for long-range solutions that would eliminate
waste discharges to Carmel Bay. Such studies are now under
way. The Central Coastal Regional Water Quality Control Board
has adopted an interim plan for water quality management in
the area, following public hearings. This plan was also the
subject of a public hearing before the California State Water
Resources Control Board, which adopted the plan in June, 1971.
It has been certified by that Board as the official State
water quality management plan for the area in accordance with
Federal regulations (18 CFR 601) governing the P.L. 84-660
construction grant program. The plan will govern all State
and Federal water pollution control actions until June 30,
1973, when a more detailed, fully developed plan will be produced
by the State. During the interim period, intensive studies
into long-range solutions for the Carmel Valley and adjacent
areas will be undertaken under the guidance of the State. A
significant contribution to this effort will be made from a
$868,000 study recently initiated by the association of Monterey
Bay Area Government, with State and Federal financial support.
Also available will be the results of the intensive monitoring
program of the County Public Health Department. These studies
will include oceanographic investigations related to marine
disposal alternatives and will examine alternatives for land
application, waste water reclamation, and reuse options.
- 15 -
-------
Objections have been raised that the discharge of treated
waste waters, through the outfall extension project, will
preclude the maintenance of "natural" conditions in Carmel Bay,
which is in an area that has been proposed for inclusion in
the expanded Point Lobos Underwater Preserve. The only possible
resolution of this objection would be to discontinue the
discharge of waste water effluent to Carmel Bay and adjacent
coastal waters. Studies are being undertaken as previously
described which will examine the need and feasibility of
such alternatives.
- 16 -
-------
1.
2.
3.
4.
5.
6.
7.
8.
9.
List of References
Abbott, Donald P. and Richard Albee
1967. Summary of thermal conditions and phytqplankton
volumes measured in Monterey Bay, California.
1961-1966.Calif. Coop. Oceanic Fish Invest.
Rep. 11, pp. 155-156.
Association of Monterey Bay Area Governments
1970. Monterey Bay Region water quality control
planning program. An application for
comprehensive river basin planning grant,
April 17, 1970, and amendment, January 15, 1971.
Various pagination.
Aubert, M. and Auber, J.
1967. Study on the diffusion of bacterial pollution
in the sea.Penn. Ar. Bed.6(50):139-149.
Bellamy, D.J., D.J. Jones, and A. Whittick
1969. Some ecological aspects of marine pollution.
Oceanology International 69. Conference.
England. 8pp.
Blum, A.
1968.
Technical considerations for the construction
of coastal outfall sewers.
Proceedings, 3d
9: 123-126. [and
International Colloquium.
Revue Internationale D'Oceanographie Medicale]
Bowen, 0. E.
1965. Point Lobos, Crown Jewel of the State Parks.
A Geologic Guide.Mineral information Service,
April.
Brooks, Norman H.
1960. Diffusion of sewage effluent in an ocean current.
Pp..246-267. In "Waste Disposal in the Marine
Environment," Pergamon Press, N.Y. '
Bumpus, Dean F., W.R. Wright, and R.F. Vaccaro
1969. Considerations on a sewer outfall off Nobska
Point. Woods Hole Oceanographic Institute
Ref. 69-87, 42pp.
California Regional Water Quality Control Board.
1967. Water Quality Control Policy. Coastal Waters,
Point Piedras Blancas to Pescadero Point.
- 17 -
-------
10. California Resources Agency
1970. Point Lobos State Reserve. Department of
Parks and Recreation.
11. California State Water Quality Control Board
1964. An investigation of the effects of discharged
wastes on kelp"! Publication No. 26,124 pp.
12. California State water Quality Control Board
1965. An investigation on the fate of organic and
inorganic wastes discharged into the marine
environment and their effects on biological
productivity. Publication No. 29, 117 pp.
13. Carmel Sanitary District Sanitary Board
1969. Ordinance No. 49. An ordinance to authorize
and order the President and Secretary of the
Sanitary Board of the Carmel Sanitary District
to execute a contract in the name and on
behalf of said District with the Pebble Beach
Sanitary District a public corporation,
relating to the development and mutual use of
the sewerage facilities of the Carmel Sanitary
District. March 27, 1969.16 pp.
14. Chartock, Michael Andrew
1969. Preliminary efforts at a quantification of
the benthos between the five to ten fathom
contours at the head of the Monterey submarine
California.Unpub.MA thesis,San Jose State
College, San Jose, California.
15. Coe, Wesley R.
1954. Geographical distribution and means of
dispersal of the bathypelagic nemerteans
found in the great submarine canyon at
Monterey Bay, California. J. Wash. Acad. Sci.
44 (10): 324-326. (Contrib. Scripps Inst.
Oceanogr. Univ., California 783).
16. Crowell, J.C.
1952. Submarine canyons bordering central and southern
California. J. Geol. 60: 58-83.
17. Dill, Robert T., Robert S. Dietz and Harris Stewart
1954. Deep-sea channels and delta of the Monterey
submarine canyon. Bull. Geol. Soc. Amer. 65:
191-194. (Contrib. Scripps Inst. Oceanogr.
Univ. Calif. 669.)
- 18 -
-------
18,
19,
20
21,
22,
23,
24
25.
26,
27,
Engineering-Science, Inc.
1968. Final report oceanographic waste disposal
studies in Monterey Bay.
Grigg, Richard W. and Robert S. Kiwala
1970. Some ecological effects of discharged wastes
on marine life"! California Fish and Game,
56(3):145-155.
Haderlie, E.G.
1970. Influence of pesticide run-off in Monterey
Bay. Mar. Pollut. Bull., n.s, 1(3): 42-43.
Institite of Marine Resources (Univ. Calif.)
1963. Kelp habitat improvement project. Final Report.
IMR Ref. 63-13, Dec. 1, 1963, 123pp.
Johnson, Ralph Gordon
1970. Variations in diversity within benthic marine
communities.Amer. Nature.104(937):285-300.
Keithley, C.L.
1968. Bathymetric Survey of Carmel Canyon. Research
paper in Oceanography, Naval Postgraduate
School, Monterey, California.
Leighton, D.L., L.G. Jones and W.J. North
1966. Ecological relationships between giant kelp
and sea urchins in southern California. Pp.
141-
153 in Proc. 5th Internat. Seaweed Symposium
(Halifax), August 25-28, 1965. E. Gordon Young
and J.L. McLachlan (editors). Pergamon Press,
N.Y. 424pp.
Longhurst, Alan R.
1969. Pelagic invertebrate resources of the California
current. Calif. Coop. Oceanic Fish Invest.
Rep. 13, 60-62.
Ludwig, Harvey F. and Ben Onodera
1964. Scientific parameters of marine waste discharge.
Pp. 37-49. In E.A. Pearson, (ed.) Advances
in Water Pollution Research, Vol. 3, Pergamon
Press, N.Y.
McLean, James H.
1962. Sublittoral ecology of kelp beds of the open
coast area near Carmel, California. Biol. Bull.
122(1):95-114.
- 19 -
-------
28. McLean, J.H.
1968. Biological Exploration at the Head of Carmel
Submarine Canyon. Abstract from Annual Reports
for 1961 of the American Malacological Union,
p. 43.
29. McLean, J.H.
1970. Biological Exploration at the Head of Carmel
Submarine Canyon.Unpublished manuscript.
30. Monterey County Health Dept., Santa Cruz
1970. County Health Dept., State Dept. of Public
Health, and Central Coastal Regional Water
Quality Control Board. A Study of the
Bacteriological Quality of Monterey and Carmel
Bays, April 1969 through May 1970.
31. Monterey County Planning Department.
1967. Monterey County Facts and Figures. Prepared
by the Planning Dept., Jan. 1, 1967.
32. Moritz, C.A.
1968. A Descriptive Survey of the Head of Carmel
Submarine Canyon.M.S.Thesis,Naval Post-
graduate School, Monterey, California.
33. Nakata, Michael M.
1970. The distribution and abundance of marine algae
in the vicinity of a sewage outfall at Carmel
California. Unpublished MS on file at Hopkins
Marine Station Library, Pacific Grove, California,
34. North, Wheeler J.
1964. Ecology of the rocky nearshore environment
in southern California and possible influences
of discharged wastes. Pp. 247-262 in E.A.
Pearson(ed.)Advances in Water Poll. Research,
Vol. 3, Pergamon Press, N.Y.
35. North, Wheeler J. and Carl L. Hubbs (editors)
1968. Utilization of kelp bed resources in southern
California. California Department of Fish and
Game, Fish Bull. 139, 264pp.
36. North, Wheeler J. and John S. Pearse
1970. Sea urchin population explosion in southern
California coastal waters.Science 167(3915):
209pp. (Jan 9, 1970)
- 20 -
-------
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
Odemar, Melvyn W., Paul W. Wild and Kenneth C. Wilson
1968. A survey of the marine environment from
Fort Ross, Sonoma County, to Point Lobos,
Monterey County"! Calif. Dept. of Fish and
Game, Marine Resources Operations Reference
No. 68-12, July 1968. 238pp.
Paine, Robert T. and Robert L. Vadas
1969. The effects of grazing by sea urchins,
Strongylocentrotus sp., on benthix algae
populations. Limnology and Oceanography
14(5): 710-719 [Sept. 1969]
^
Peckham, Vern 0. and James H. McLean
1961. Biological exploration of the Carmel submarine
canyon. Abstract list of species only, on
p. 43 of 1961 Ann. Dept. Amer. Malacological
Union. (McLean now at Los Angeles County Mus.
Nat. Hist, has only copy of MS.)
Rambow, C.A. and P.V. Hennessy
1965. Oceanographic studies for a small wastewater
outfall. Water Poll. Control Fed. Jour.
37(11): 1471-1480. [Nov. 1965].
Rawn, A.M., F.R. Bowerman and Norman H. Brooks
1960. Diffusers for disposal of sewage in sea water.
J~. Sanitary Engineering, SA 2 (24-24) . March
1960, pp. 65-105.
Reish, Donald J. (editor)
1969. Biology of the oceans.
Belmont,Calif.
Dickenson Publ. Co.,
Russell, Findlay E., and Paul Kotin
1957. Squamous papilloma in the white Croaker. Nat.
Cancer Inst., Jour., Vol. 18, No. 6, pp. 57-861.
Santini, D.B.
1965. Effect of pollution on some surface populations
of rocky substratum. Comm. Internat. pour
I1Exploration Sci. de la Mediterranee, Monaco,
April, 1964. Pp. 127-131.
Stanford University
1970. Final Papers Biology 175h. Unpublished MS on
file at Hopkins Marine Station Library, Pacific
Grove, Calif.
Shepard, F.P. and Dill, R.F.
1966. Submarine Canyons and Other Sea Valleys.
McNally and Company, 381 pp.
Rand
- 21 -
-------
47
48,
49,
50,
51,
Superior Court of the State of California
1971. Order No. 68437 denying injunction and sustaining
demurrer in and for the County of Monterey.
Thomas J. Hudson, Plaintiff vs. Edward F. Dibble,
Carmel Sanitary District, et al., Defendants,
April 19, 1971, 3pp.
Trumbauer, D. S.
1966. A coliform bacteria survey of Monterey Bay off
Del Monte beach!Unpublished MS thesis, USN
Postgrad. Sch., Monterey, Calif.
Tsai, C.
1968. Effects of chlorinated sewage effluents on
fishes in upper Patuxent River, Maryland.
Chesapeake Science 9(2):83-93.[June 1968].
Turner, Charles H., E. E. Ebert, R. R. Given
1965. Survey of the marine environment off shore of
San Elijo Lagoon, San Diego County. California
Fish and Game, 51(1):81-112.[Jan. 1965].
Turner, Charles H., E. E. Ebert and R. R. Given
1966. The marine environment in the vicinity of the
Orange County Sanitation District's ocean
^
ill
52
53
outfall.Calif. Fish and Game 52(1):28-48.
[Jan. 1966].
Turner, Charles H., Earl E. Ebert and Robert R. Given
1968. The marine environment offshore from Point Loma,
San Diego County.Calif.Fish and Game,Fish
Bull. 140, 85pp.
Turner, Charles H. and Alec R. Strachan
1969. The marine environment in the vicinity of the
San Gabriel River mouth. California Fish and
Game 55(1):53-68 [Jan. 1969].
54
Wallin, S. R.
1968. The Sediments
in the Head of the Carmel
Submarine Canyon. M.S. Thesis, Naval Post-
graduate School, Monterey, California.
55.
White, Emil (editor)
1964. Circle of enchantment:
Big Sur, Carmel, Pebble
Beach, Monterey, Pacific Grove.
Big Sur, Calif.
EmilWhite,
- 22 -
-------
56. Whitmore, Robert
1966. Molluscan composition at the Pleasure Point
sewer outfall.Unpub.stud, rep., Grad.
Marine Ecology, Moss Landing Marine Labs, Moss
Landing, Calif.
57. W. M. Rack Laboratory of Environmental Health Engineering
(Calif. Inst. Tech.)
1968. Kelp habitat improvement project. Annual
J6C'
30,
Report, July 1, 1967 - June 30, 1968.123 pp.
58. Young, Parke H.
1964. Some effects of sewer effluent on marine life.
Calif. Fish and Game.50(1):33-41.
[Jan. 1964].
59. Zats, V. I.
1965. Effect of oceanographic factors on the
contamination of coastal waters (A brief
review of Soviet and non-Soviet literature).
[English edition, May 1966], 5(3) : T^9~.
- 23 -
-------
Appendix A
I Receiving Water Monitoring Program for Carmel Bay.
-------
\OSt
STATE Of CALIFORNIA— RESOURCES AGENCY
RONAID REAGAN, Co.trnof
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD-
CENTRAL COAST REGION
.238 BROAD STREET
SAN. IUIS OBISPO, CALIFORNIA 73401
October 29, 1971
Mr. David D. Kennedy
Kennedy Engineers ;
657 Howard Street
San Francisco, California
Dear Mr. Kennedy:
A copy of the October Receiving Water Monitoring Report for Carmel Bay
has been received in this office and studied by Tom Bailey and Jay Nighs-
wonger of our staff. They agree that some modifications should be in-
stituted to provide more significant information. Therefore, please
incorporate the following amendments into the program:
1. Use triangulated compass bearings to locate sampling stations
instead of permanent markers.
2. Macrofauna and macroflora to be identified and counted, but not
removed, at a rock formation near the actual sampling station.
The rock formation should be identified so it can be used in
future surveys.
3. Samples collected at each station for salinity determination at
the surface, mid-depth, and just off the bottom.
4. Total nitrogen and total phosphorus determinations made on the
sediment at Cl-A and Cl-C stations.
5. Vertical plankton tows may be performed at your discretion.
If you have any questions or comments, please contact Jay Nighswonger
of this office.
•* ^.
Very^truly yours,
KRJ
jfj!n
o n i u
cc-Y-T-0, Monterey
O.S.I., StaBarb.
KENNETH R. Ji
Executive Officer
-------
STATE OF CALIFORNIA—RESOURCES AGENCY
IONAIO REAGAN. Conrnor
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD-
, CENTRAL COAST REGION
V 218 BROAD STREET
SAN IUIS OBISPO. CALIFORNIA 93401
^DC-
19, 1971
Carmel Sanitary District
P. 0. Box 83
Carmel, California 93921
Gentlemen:
Enclosed is a copy of the monitoring and reporting program
for Carmel Sanitary District. This program supersedes that
adopted December 13, 1S68 and should be attached to the requirements
for sewage discharge adopted on that date.
If you have any questions, please write or call this office.
Very truly yeurs,
KRJ
JN:h
Encl.
cc-Pebble Beach Sanitr.ry Dist.
Bureau of Sanitary Enginearing
Dept. of Water Resources
Dept. of Fish & Game
Dept. of Parks & Recreation
Monterey County Health Dept.
Monterey County Planning Dept.
Assn of Monterey Bay Area Govti
ETH R. JONES
Executive Officer
-------
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
CENTRAL COAST REGION
MONITORING AND REPORTING PROGRAM
FOR
CARMEL SANITARY DISTRICT
EFFLUENT MONITORING
All effluent samples shall be collected at the locations and frequency
specified. Composite samples may be taken by a proportional sampling device
approved by tha Executive Officer or by grab samples composited in propor-
tion to the flow. In compositing grab samples, the sampling interval shall
not exceed one hour. The following shall constitute the effluent moni-
toring program:
Constituent
-Chlorine residual
^Settleable solids
Grease
Coli€orm organisms
-Suspended solids
^pH
Total hardness
Sodium & Potassium
Alkalinity
Chloride
Sulphate
Total Nitrogen
Phosphate
Total dissolved solids
Specific conductance
Toxicity Bioassay
Maximum daily flow
Mean dnily flow
Units
Mg/1
Ml/1
MgA
.MPN/100 ml
Mg/1
Units
Mg/1
it
n
umhos/cm^
96-hr TLm
MGD
Type of
Sample
Grab
it
8-hr compos
Grab
8-hr compos
t> ti
it 11
it n
n i.
tt n
tt tt
Location Sampling
of Sample Frequency
Outfall manhole
Effluent Pump
Effluent Pump
Outfall manhole
Effluent Pump
Daily
ti
Monthly
Weekly
ti
11
tt
it
n
it
it
it
ti
ii
ti
11
tt
it
it tt it it
" " Unchlorinated
n
11
Annually
it
n
n
it
ti
n
it
Daily
n
-------
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
CENTRAL COAST REGION
******
RECEIVING WATER MONITORING
The receiving water monitoring program shall be conducted as outlined.
When the current study has been completed, the program may be revised to
take advantage of more significant data.
Sediment and benthic samples shall be collected from the following
stations:
Station Description
Transect - Cl Beginning at present outfall at high water mark and
extending on a straight line with outfall into 60
feet of water.
Transect - 2 Beginning 500 feet north of present outfall at the
high water mark and extending on a line parallel
with outfall to the 00 foot depth.
Transect - 3 Beginning 500 feet south of present outfall at the
high water mark and extending on a line parallel
with outfall to the 60 foot depth.
Transect - CM- Beginning at Granite Point at the high water mark
and extending NW into 60 feet of water.
Current meter
study stations
C5 In vicinity of end of proposed outfall.
Environmental conditions of the water column and ocean floor in the
vicinity of the outfall shall be determined each April, September and
December by the following monitoring procedures:
A. Chemical content of ocean floor.
1. Obtain three cores (minimum 6 inches) of ocean bottom from
both the 20 foot and l!0 foot depth on each transect. (Diver-
held lij inch plastic tubes)
2. Analyze top inch of two cores composited for C.O.D., sedi-
ment grain size, and inorganic fraction of substrate. The
remaining core should be dried, labeled, and stored for
future analysis, if needed.
21 -U- \*)~\
-------
B. Ecological Conditions of the Benthos.
1. Permanent markers shall be established on the bottom along
each transect at the 20 foot depth, 40 foot depth, and 60
foot depth. Each study area shall be defined by attaching
a 6 foot line to the marker and traversing a circle with
this line as its radius.
2. Within each study area the following shall be accomplished:
(a) Record general description of the bottom area.
(b) Record water depth.
(c) Record water temperature.
(d) Estimate water clarity (horizontal distance that
objects are visible).
(e) Identify and enumerate macrosopic plants and animals
(including fish).
(f) Skim approximately one liter of sediment from the top
1 to 2 inches of bottom into a wide mouth jar. This
material shall be washed through a 1.0 mm screen. Those
organisms retained on the screen shall be preserved in
S% formalin in sea water and taken to the lab for micro-
scopic analysis. Identify and enumerate organisms to
species where taxonomic keys permit. Sediment shall be
taken from a different area each time sampled.
3. The macroscopic plants and animals along the intertidal portion
of the transect shall be identified and enumerated during a
time when the tides are low.
4. Water columns above the permanent markers shall be measured
for turbidity just below the surface, at mid-depth, and just
off the bottom. Samples shall be taken to the lab and run
on a candle turbidimeter.
5. A current study shall be carried out for a period of one year
to determine the velocity, direction, and mass transport of
water in the vicinity of the anticipated outfall. This shall
be accomplished by stationing a continuous recording current
meter in the vicinity of the proposed discharge point with the
probe at mid-depth. The meter should be located in an area
that is readily accessible and will avoid entanglement with
kelp.
In conducting the receiving water s-impling, a log should be kept of
the receiving water conditions. Attention should be given to the presence
or absence of:
a. Floating or suspended matter. b. Discoloration
-------
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
CENTRAL COAST REGION
GENERAL MONITORING AND REPORTING PROVISIONS
»*«»•»»*•
GENERAL PROVISIONS FOR SAMPLING AND ANALYSIS
Unless otherwise noted, all sampling, sample preservation, and analyses shall
be conducted in accordance with the current edition of "Standard Methods for
the Examination of Water and Waste Water" or approved by the Executive Officer.
All analyses shall be performed in a laboratory certified to perform such analyses
by the California State Department of Public Health or a laboratory approved by
the Executive Officer.
All samples shall be representative of the waste discharge under the conditions
of peak load.
GENERAL PROVISIONS FOR REPORTING
For every item where the requirements are not met. the discharger shall submit
a statement of the actions undertaken or proposed which will bring the discharge
into full compliance with requirements at the earliest time and submit a time-
table for correction.
By January 30 of each year, the discharger shall submit an annual report to the
regional board. The report shall contain both tabular and graphical summaries
of the monitoring data obtained during the previous year. In addition, the dis-
charger shall discuss the compliance record and the corrective actions taken or
planned which may be needed to bring the discharge into full compliance with the
waste discharge requirements.
The discharger shall file a written report within 90 days after the average dry-
weather flow for any month that equals or exceeds 75$ of the design capacity of
the waste treatment or disposal facilities. The report shall contain a schedule
for studies, design, and other steps needed to provide additional capacity or
limit the flow below the design capacity prior to the time when the waste flow
rate equals the capacity of the present units.
-------
REPORTING
Effluent monitoring reports shall be submitted to the regional
board monthly by the 15th of the following month. The first report
shall be due October 15, 1071. Receiving water monitoring reports
shall be submitted to the regional board 45 days from the end of the
month in which the monitoring was accomplished. The first report shall
be due November 15, 1971.
In reporting the monitoring data, the discharger shall arrange the
data in tabular form GO the date, the constituents, and the concen-
trations are readily discernible. The data shall be summarized to
demonstrate compliance with with waste discharge requirements.
ORDERED .
Executive <&*"ricer
July 19, 1971
-------
31
shells and
gravel
21
17
113
35
sand
179
and mud
60
40
1000
2000
3000
4000
FEET
SOUNDINGS IN FATHOMS
N
-20-
TRANSECT5
CARMEL BAY RECEIVING WATER MONITORING
CARMEL SANITARY DISTRICT
OCTOBER 1971
PACIFIC ENVIRONMENTAL LABORITORY
SAN FRANCISCO
-------
Appendix B
Comments received on the draft Environmental Impact Statement.
-------
COUNCIL OF
MONTEREY BAY, INC
September 21, 1971
Mr. Paul De Falco, Jr.
Acting Regional Administrator
Environmental Protection Agency
760 Market Street
San Francisco, California 94102
Dear Mr. De Falco:
Your letter of September 13, 1971 forwarded a copy of the
Environmental Statement for the Carmel Sanitary District's Ocean .,
Outfall Extension Project and solicited our comments.
As a local civic organization concerned with the environ-
mental integrity of the Monterey Bay area, v:e have followed the
subject oroject closely for several years, v.e apree generally
with the conclusions reached in your study and support the con-
tinuation to completion of the present construction.
We are aware of the expressed desire of many of our citizens
for advanceJ treatment and/or land disposal of treatment olant
effluents. Vie are also of the opinion that this will eventually
come to be and do not consider the present outfall construction
to be inconsistent with longer-range plans. V,e know that the
treatment plant must have an ocean outfall for overload and emer-
gency conditions in any event. ' e consider the prasent action
v;ill provide a creat improvement over the existing outfall line.
We are further convinced that the oroperly treated effluents of
the treatment olant, in the present and projected volumes will
not have a significant inpact on the ecolocy of the Cartel Say.
We further consider that the nrooosed monitor system will -rsvide
adequate safeguards against any najor adverse effects.
ml
1321 MONTEKEY/'SAUNAS HIGHWAY MONTEREY CALIFORNIA 93940 (408) 375-5462
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
REGIONAL OFFICE
September 30, 1971
OFFICE OF
Mr. Paul De Falco, Jr.
Acting Regional Administrator
Environmental Protection Agency
760 Market Street
San Francisco, California 94102
Dear Mr. De Falco:
This letter will acknowledge receipt of the Draft Environmental
Impact Statement on the ocean outfall extension project of the
Carmel Sanitary District, Carmel, California.
It does not appear that any problems of health significance
related to this department will result from the project.
We appreciate the opportunity to review the Draft Environmental
Statement.
Sincerely yours,
Robert Coop
Regional Director
-------
STATE OP CAUFOtNIA—tESOUtCCS AOB4OT
OCT14 fc'C'l
BONAID REAGAN, Go.
CAUFORNIA REGIONAL WATER QUALITY CONTROL BOARD-
CENTRAL COAST REGION
m» KOAD SnBT
SAN luis otnro. CAUFOINIA 93401
October 13, 1971
Mr. Paul De Falco, Jr.
Regional Administrator
Environmental Protection Agency
Region IX
760 Market Street
San Francisco, California 9U102
Dear Sir:
Reference is made to your Draft Environmental Statement concerning
the Ocean Outfall Extension Project (WPC-CAL-t68), Carmel Sanitary District,
Carmel, California. We have no adverse comments concerning this report.
Very truly yours,
t/—^
KENNETH R. JONES
Executive Officer
KRJ/mls
End.
co: State Water Resources Control Board
DEPARTMENT OF THE NAVY
OFFICE OF THE OCEANOGRAPHER OF THE NAVY
THE MADISON BUILDING
732 N. WASHINGTON STREET
ALEXANDRIA. VA. 22314
3 SECT)
Hit
IN REPLY REFER TO
1548
12 October 1971
Mr. Paul De Falco, Jr.
Acting Regional Administrator
Environmental Protection Agency
Region IX
760 Market Street
San Francisco, California 94102
Dear Mr. De Falco:
Thank you for your letter of 13 September 1971 requesting comments
on the draft environmental impact statement on the ocean outfall
extension project of the Carmel Sanitary District, Carmel, California.
The draft environmental Impact statement is extremely well-written
and reflects an orderly, In-depth analysis of the problem of waste
discharge in the Carmel, California region. The extended outfall
project represents a considerable improvement over the existing
system.
In reviewing the adequacy of the assessment contained in this draft
statement the following points are noted:
The quality of the effluent to be discharged from the proposed
extended outfall is not clearly stated.
There is Insufficient data presented in,the assessment to
support the effluent dilution and diffusion estimates presented.
Estimates of these parameters depend upon both the density of the
effluent and the circulation dynamics of the receiving waters. It
is recommended that background data to support these circulation
estimates be Included in the environmental Impact statement.
£rely youra,
W. F. REED,
Captain, U. S. Navy
Assistant Chief of Staff
for Environmental Quality
By direction of the Oceanographer
of the Navy
-------
United States Department of the Interior
GEOLOGICAL SURVEY
Water Resources Division
3>»5 Middlefield Road
Menlo Park, CA 94025
October 5, 1971
Mr. Paul DeFalco, Jr., Director
Environmental Protection Agency
Region IX "
760 Market Street
San Francisco, CA 9H102
Dear Mr. DeFalco:
We have reviewed the draft of the Environmental Statement by the
Environmental Protection Agency on the Ocean Outfall Extension
Project for Carmel Bay. It is fairly comprehensive and adequately
considers most of the possible impacts on the environment. However,
we offer several specific points which we feel should also be
considered.
1. Were circulation patterns, density currents, and seasonal changes
in water temperatures taken into account in selecting the location of
the outfall? Discharge of the Carmel effluent to deeper water does
not in itself assure elimination of near-shore pollution problems if
strong landward currents or other circulation anomalies are present
near the outfall location.
2. The statement discusses a comprehensive monitoring program for the
area around the outfall to detect environmental damage. We think details
of the proposed monitoring program should be included in the statement,
particularly in light of the unique nature of Carmel Bay and its native
habitat for birds such as the pelican and mammals such as the otter.
Also, there is no mention of the monitoring program planned for the
effluent itself. Exotic toxicants, including heavy metals and pesticides,
which are normally not monitored in domestic effluents should be considered
for any effluent monitoring program designed for the Carmel discharge.
3. Will recent zoning decisions in the Carmel area, which appear to
make increased residential and commercial development a certainty,
have appreciable effect on the quality and quantity of waste waters
discharged to the Carmel plant? If so, were these anticipated changes
examined during assessment of feasibilities for "other disposal
alternatives?
The foregoing comments are provided informally for technical assistance
and are not intended to represent the position of the Department of the
Interior.
Very truly yours,
W. W. Hastings
Regional Hydrologist
Pacific Coast Region
-------
DEPARTMENT OF TRANSPORTATION «"•"..
UNITED STATES COAST GUARD ......
STATE OF CALIFORNIA-HEALTH AND WELFARE AGENCY
KONALD REAGAN. Governor
DEPARTMENT OF PUBLIC HEALTH
2151 BERKELEY WAY
BERKELEY 94704
October 6, 1971
: unr 1971
Mr . Paul De Falco , Jr .
Acting Regional Administrator
Environmental Protection A^snc/, Ae^ion IX
?60 Market Street
San Francisco r California vli1o£
Dear Mr. De Palco:
Reference is made to your letter of 13 -September 1",71 and
the draft environmental impact statement oil the ocean
outfall extension project of the Car-mel 3unitary District
which was included with it. '.!e have reviewed the statement
and have no comment on it. Thank you for requesting our
views .
Sincerely yours,
3. K.
Captain, ". j. Coast Guard
Chief of otaff
Mr. Paul De Falco, Jr.
Regional Administrator
Environmental Protection Agency
Region IX
760 Market Street
San Francisco, CA 91*102
Dear Mr. De Falco:
The environmental impact statement on the ocean outfall extension project
of the Carmel Sanitary District, Carmel, California has been reviewed in
accordance with your September 13, 1971 letter of request.
Die California Department of Public Health concurs in the EPA evaluation
of the environmental Impact of this project. It is understood that this
project is an interim solution to an immediate pollution problem and that
additional measures will be taken as necessary to protect the marine
environment.
/' John tf. 'Heslep, Ph.D.
i/ Deputy Director for
Environmental Health and
Consumer Protection
Carmel Sanitary District
Central Coast R.W.Q.C.B.
Monterey County Health Dept.
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3 ia
K. 8. PBASBB.M.D.
oincnt or PUBLIC BIALT
«•«
434-7627
COUNTY OF MONTEREY
DEPARTMENT OP PUBLIC HEALTH
1270 NATIVIDAO BOAD
SALINAS. CALIFORNIA 63904
P.O.BOX 2137
BflAHCH OFFICES:
HOKTEBET . . .
1200 AOUAJ1TO ROAD
KING CITT. . . .
CITT BALL
October 12, 1971
Mr. Paul De Falco, Jr.
Regional Administrator
Environmental Protection Agency
Region IX
760 Market Street
San Francisco, California 94102
Dear Mr. De Falco:
He have reviewed the Environmental Statement on the Ocean Outfall
Extension Project of the Camel Sanitary District, Camel, California
(WPC-CAL-468).
He wish to bring to your attention the fact that the public health
standards are not mentioned at all in this report. On page 5 it states,
"At the present discharge point the existing biological damage, health
hazard, and unesthetic condition can be eliminated." Since health
hazards are one of your major reasons for the removal of the outfall at
the present location, it should be brought out publlcally that the
Monterey County Health Department and the State Health Department were
the agencies responsible for monitoring and enforcing water contact sports
standards for the protection of public health of the people utilizing these
facilities. Also, no mention was made of the Health Department's coordinated
study that brought out the pollution of Monterey and Camel Bays and
Initiated all this action. Enclosed Is a copy of the report. —
There Is mention of the Regional Water Quality Control Board in relation-
ship to cease and desist orders; of Hopkins Marine Station's biological
study; of the State Water Resources Control Board in relationship to grants;
and the Association of Monterey Bay Area Governments in its waste water
management study. Therefore, it would only be consistant and uniform In
your references that whenever water contact sports and health hazards are
mentioned that public health agencies should be mentioned.
We are presently monitoring all the Monterey-Camel Bay shore waters twice
a week. We are sampling all the estuaries in Monterey County twice a
nonth. Through contract with Hopkins Marine Station, we are collecting
and analyzing sanples twice a month of waters near outfall lines. It may
be of Interest to you that during our one-year study, we sampled the
off-shore waters of Camel Bay directly in front of the present outfall
1000 feet out, and 1000 feet left and right of the outfall.
Paul L>e Falco, Jr.
Environmental Protection Agency
- 2 -
October 12, 1971
Recognizing that water contact sports have changed and that skin diving
and surfing are now using all bay waters way beyond the shore line, we
have started this program of off-shore sampling. When the new Camel
outfall is constructed, samples will be collected by members of the
diving club at Point Lobos twice a week for our department to analyze
from stations directly in front and 1000 feet both directions of the
outfall. The purpose is to continue the surveillance of water contact
sports and public health standards. We are also doing a routine twice
a month sampling of the Carmel River.
We assure you that the public health departments have been involved in
environmental concern since back in the days of the bubonic plague
prevention and will continue to work actively in environmental matters.
Please feel free to contact our office at any time concerning the
problems In our jurisdiction.
Sincerely,
R. S. Fraser, M.D.
Director of Public Health
County of Monterey
WW:ra
Encl.
Walter Wong
Director of Environmental Health
-------
OCT .1 4 REC'D
Carmel Sanitary District
CARMEL RANCHO SHOPPING CENTER
POST OFFICE Box 63
CARMEL. CALIFORNIA 93921
(4OS) 624-1248
13 October 1971
Regional Administrator
Environmental Protection Agency
Region IX
760 Market Street
San Francisco, California
Subject:
Ocean Outfall Extension Project
WPC-CAL-468
Gentlemen:
We have reviewed the draft of the Environmental Statement for
the subject project dated September 1971. The draft statement appears
to present and summarize a complex situation 'generally quite well,
although there are several items contained therein which we wish to
clarify and comment on. Specific comments and clarifications are
listed below with references to the page and paragraph of the draft
statement. A general comment follows the specific comments and
clarifications.
Page. Paragraph
2, 1
2, 3
2, 5
3, 3
Comments
The District has been supplying effluent
for irrigation purposes since 1947.
Bacterial densities adjacent to the out-
fall have been in full conformance with
Discharge Requirements since December 1969
except during periods of high Carmel River
outflow, and evidence shows these conditions
cannot be attributed to the Sanitary District.
The District's Master Plan, which recom-
mended activated sludge treatment, was
prepared in 1967 and adopted in April 1968.
This took place prior to the problems of
high bacterial levels in the receiving waters.
The comprehensive monitoring program is a
condition of the grant for the new treatment
facilities (WPC-CAL-530), not the outfall
project. Item (2) of the three additional
improvements does not have "and" at the e'nd.
- 2 -
Page. Paragraph
4, 2
5, 2
5, 3
6, 2
8, 4
9, 3
11, 6
Comments
The construction contract amount is $408,400.
We feel "possibly" should be added to the 4th
line to read, "point, and possibly in the Bay
as a whole."
A comment regarding the installation of the
pipe in the rock formation for anchorage to
assure permanence and protection from storms
and sand movement would be appropriate.
We believe "in the Bay and" should be added
to the 13th line to read, "Bacterial densities
in the Bay and at the shoreline should be
readily...".
Some additional discussion regarding the
effects of Carmel River discharge and the
other minor tributary streams would be appro-
priate at this point. We feel that additional
emphasis should be given to the effects of
existing and future development and uses
adjacent to the Bay. In view of the proximity
of the discharge location to the mouth of the
Carmel River, some discussion regarding the
effect of fresh water on marine biological
communities might also be desirable. The
District's discharge in 1985 has been estimated
to be approximately 5% of the River's natural
yearly discharge.
Based on a recent appraisal by the State of
California, the adjacent land would cost in
excess of $3 million and it is reasonable to
assume that other suitable land would be in
a similar price range. Necessary pumping,
storage and piping has been estimated to cost
an additional $300,000.
The first bond issue election for $1,500,000
received a 64% affirmative vote, but failed
to obtain the 2/3 vote required for general
obligation bonds. Plans for a secondary treat-
ment facility were being prepared for the
project to be funded by the $1,500,000, but
the project would have been contingent on
receiving Government grants. The second bond
election for $2,400,000 would have funded the
improvements regardless of Government grants.
-------
- 3 -
Page, Paragraph Comments
11, 6 (cont'd.) The District had a flexible Implementation
plan contingent on Government grants* and it
appeared confusion in the minds of the voters
was the result.
It would be desirable to include a comment in the statement regard-
Ing the flexibility in the District's improvement program. The instal-
lation of a moderate length outfall in conjunction with a high level of
treatment- does not commit the District to permanent ocean disposal while
a lower level of treatment with a long outfall would be more likely to do
so. The prompt Installation and use of the new outfall extension will
provide an additional factor of safety for the receiving waters until
sufficient factual data are available for long-term planning decisions.
Consideration and inclusion of these comments where deemed proper
should help complete a correct and comprehensive Environmental Statement
for this project. An expeditious and favorable decision regarding release
of grant participation funds will greatly assist the Carmel Sanitary
District in its efforts towards environmental protection and will be
beneficial to both the local taxpayers and the general public.
Very truly yours,
CABMEL SANITARY DISTRICT
Richard R. Kennedy Q
District Engineer
RRK:pm
cc: State Hater Resources Control Board
-------
U.S. DEPARTMENT OF COMMERCE '""*••••- .-
National Oceanic and Atmospheric Administration,/^
Southwest Region
300 South Ferry Street
Terminal Island, California 90731
MONTEREY PE
COLLEGE
»0 FREMONT, ModBIREY,' CALIFORNIA 93940
75-3821
October 13. 1971
C E o • c E J. F A u L
PRESIDENT AND SUPERINTENDENT
Mr. Paul DeFalco, Jr.
Acting Regional Administrator
Environmental Protection Agency
760 Market Street
San Francisco, CA 94102
Dear Mr. DeFalco:
We have reviewed your draft environmental statement on the
Ocean Outfall Extension Project (WPC-CAL-468) , Carmel Sanitary
District, Carmel, California.
The draft statement indicates the ocean outfall sewer exten-
sion is an interim measure to relieve existing pollution problems
and that the principal environmental impact will be to lower
existing conditions of pollution near the shore line in Carmel
Bay. We note also that long-range alternate solutions to this
problem are currently under study by a regional water quality
planning agency with State and Federal financial support.
There will be some damage to marine life during construction
of the outfall line. However, it is expected that reestablish-
ment of near natural conditions would occur once construction
of the line is completed. We have no serious adverse comments
on the draft statement.
We appreciate this opportunity to review this statement on the
proposed project.
Sincerely,
Frederick K. Cramer
Acting Regional Director
cc: F34, Bill Newman, NMFS, Arlington, VA
BOAKD OF TRUSTEES
RALPH ATKINSON, CHAIRMAN
LEWIS L. FexroN, CLERK
RUSSEL.HANSEN
MAJ. SHERMAN Surra
MRS. RICHARD ELDRED
13 October 1971
Mr. Paul De Falco, Jr.
Acting Regional Administrator
Environmental Protection Agency
Region IX
760 Market Street
San Francisco, California 94102
Dear Mr. Falco:
We appreciate the opportunity to review the draft of the
environmental impact statement on the outfall extension
project in Carmel Bay.
In general, we feel a sincere attempt was made to record
and assess most points of view. However, one prominent
omission is the alternative of no extension to the outfall.
We believe there is enough supportive evidence for this to
have been given some serious consideration.
We are disappointed by the time of release of the document.
This draft has been circulated long after the pipe construc-
tion began and, therefore, for us to spend time writing a
detailed critique seems to be an unproductive activity.
The decision to build the extension has been made on what
appears to be flimsy evidence. The money has been spent.
The newspaper has told the public that E.P.A. has approved
the project on the basis of draft.
We would be pleased to contribute more detailed, constructive
criticism of future draft reports if they are published in
time to be effective.
Sincerely,
WT:nd
Winona Trason, Ph.D.
Chairman, Life Science Division
-------
;• r--1 P r.j.
MONTEREY COMMITTEE FOR ENVIRONMENTAL INFORMATION
(II) MONTEREY PENINSULA COLLEGE 980 FREMONT
V^ ^A. >/\. J MONTEREY, CALIFORNIA Cej!3£40iuti[#i0^tu52 7<7f$u
October 14, 1971.
UNITED STATES
DEPARTMENT OF THE INTERIOR
NATIONAL PARK SERVICE
WESTERN REGION
OCT1 9
IN REPLY REFER TO:
A98
(WR)CPF
October 15, 1971
Mr. Paul De Falco, Jr.
Acting Regional Administrator
Environmental Protection Agency
Region IX
760 Market Street
San francisco. California 94102.
Dear Mr. Falco i
Enclosed is a copy of the comments made by the members
of this committee of the M. C.E.I, on the draft of the
environmental impact statement on the outfull extension
project in Carmel Bay.
Attached as an addendum is the recently received report
from Kennedy Engineers on their cureent study in Carmel
Bay and kome preliminary comments on it.
Sincerely,
Wei ton Lee, Eh. D.
Winona Trason. Ph.D.
Co-Chairmen, Water Pollution
Committee
Mr. Paul De Falco, Jr.
Acting Regional Administrator
Environmental Protection Agency
760 Market Street
San Francisco, California 94102
Dear Mr. De Falco:
The following comments are made regarding your Draft Environ-
mental Impact Statement on the ocean outfall extension project
of the Carmel Sanitary District, Carmel, California.
This statement has been extremely well prepared and you should
be commended for its completeness, conciseness and objectivity.
We have no objections or comments to make regarding this
statement except to express our concern for the possibility
of pollution to or irreparable damage to a possible future
State park addition. We, therefore, urge you to continue
your close cooperation with the California State Park System
and with all pollution control agencies involved.
Your proposed program of continued study and improved district-
wide control, if implemented, will be a model of environmentally
responsible action for the rest of the State.
Thank you for the opportunity to review this statement
Sincerely yours,
Dan
Acting Direc
Western Region
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-2-
MONTEREY COMMITTEE FOR ENVIRONMENTAL INFORMATION
MONTEREY PENINSULA COLLEGE 980 FREMONT
MONTEREY, CALIFORNIA 93940 (408) 372-7798
Water Pollution Study Group
October 12, 1971
COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
PREPARED BY THE ENVIRONMENTAL PROTECTION AGENCY ON THE
OCEAN, OUTFALL EXTENSION PROJECT OF THE CARMEL SANITARY
DISTRICT. CARMEL. CALIFORNIA.
The Water Pollution Committee of the Monterey Committee for
Environmental Information has reviewed the draft of the Impact
statement on the ocean outfall extension project at Carmel. It
Is clear to us that a sincere effort has been made to ascertain
all the aspects of the problem in a fairly short time. The mem-
oers ol this committee appreciate the opportunity to review the
results of that effort and hope that the following comments will
be accepted as a collective effort from scientists who have spent
a good deal of time over a period of years studying the Carmel-
Monterey waters.
Among other concerns about the report as a whole is that there
are many unsupported general statements confirming the assump-
tion that the building of the outfall is a desirable event..
Many of these generalizations may have unjustifiably soothed the
uninformed residents of the area. We have requested data from
Kennedy Engineers on many occasions during this past year with
complete lack of success. ( For new information see page ).
These generalizations have been pointed to in the detailed section
oi this critique.
The alternative of having secondary treatment and release into
the surf without the long and expensive outfall was omitted from
consideration. To us, this is a glaring omission since the out-
tall line will be closer to Monastery Beach which was closed
previously because of contamination. This, with evidence that
at certain times of the year the drift is from the outfall area
towards Whaler's Cove and Monastery Beach fsee detailed critique)
and that there is no case locally where extended outfalls of even
greater length have provided the protection that this one is said
to provide, causes this committee to question seriously the wis-
dom of building the extended outfall into Carmel Bay. Is it not
possible that the source of the problem is merely being moved off-
shore at a cost of $480,000?
The terms "interim","long-term","short tern" are used throughout
without any indication as to what dimension of time this might be.
A detailed critique followsi
Page 1. Last sentence. This statement gives the impression that
the pipe is always under water at its terminal end when, in fact,
it is exposed at low tide. There the "4 feet" referred to must
mean from high water. Does the 200'figure also take reference
from high water?
Page 2. Fourth paragraph-last sentence. The major kelp bed
plant is Macrocystis. This is significant because this is the
predominant alga in the area and if it is damaged, a major change
in the life in the bay would result.
Fourth and Fifth paragraph. The position of the paper is
that extending the pipe into deeper water will achieve an"improved
dispersion and dilution". Can proof for this statement be pro-
duced? It is our opinion that without knowledge of the character
of the water, this prediction cannot be made. At other places in
the Monterey area where pipes are 300 to 800 feet off shore, there
is on-shore contamination. Also, the intercidal surf produces
more aeration and mixing than subtidal waters and intertidal life
is hardier than subtidal. Where will the sludge go?
Page 3. First paragraph-second sentence. It appears to us that the
pipe will not be 600* from mean sea level because of the dog-leg in
the 600' pipe. It would appear to be 300'-400' from shore.
Second paragraph - last sentence. Will the E.P.A. guaran-
tee that only secondary treated sewage will pass through the pipe?
If not, who will? We are concerned because information from one
of our members who had a converaation with Kennedy Engineers says
the present plans for the outfall are uncertain but that hooking
up the primary system in the meantime has not been rejected.
Page 5. Second paragraph- second sentence. Can this statement re-
garding the elimination, of undesirable effects at the existing
discharge be supported with any proof? We have not been able to
obtain same from the engineers.
Second paragraph - last sentenceWhat is abnormal about
the Bay water salinity and temperature? We have been unable to
get supporting data on this. And how would the proposed pipe
eliminate the problem? Information from Hyperion Plant indica-
tes an anomaly over the outfall (Brown '71).
Last paragraph - Macrocvstis and Pterveophora are not
annuals.
Page 6. second paragraph " Second sentence. What evidence is
there for the lack of a vertical temperature gradient? We have
been unable to substantiate this.
Second paragraph - sixth sentence. The assertion is
made that rapid dispersion will produce a dilution of 2000 to 1.
Have currents and winds been taken into account? What other
evidence is there that this will occur? Don Rich of the Point
Lobos Preserve has observed that each year when the mouth of
the Carmel River is opened to the sea in late November and
December that the debris and sand drifts to Whalers Cove.
Also, drift bottles released by Hopkins Marine Station students
in Carmel Bay drifted on shore. In the absence of counter evi-
dence, these data are sufficient to cause us concern about the
direction of flow and resulting dilution.
-------
-3-
Second paragraph - last sentence. It should be noted that
In case of a breakdown, dilution will be the only factor and in
all Monterey Bay no outfall has provided this kind of safety.
Page 7. FiAt paragraph - second sentence.
in Southern California.
There are no sea otters
First paragraph - last sentence. Why "naturally" smaller?
Second paragraph-last sentence. Some work has been done
in this area (Halstead "70, Young, '64).
Page 8. Second paragraph - first sentence. In our opinion this
'dilution solution' is questionable at best in light of the total
lack of.supporting data.
Second paragraph - second sentence. Recent studies at
Hopkins Marine Station at the Monterey Outfall showed that second-
ary treated sewage increased nutrient levels in the effluent rather
than reduced them.
Page 9. First
cond sentence. "Short-term"? "Interim"?
An alternative omitted here is no pipe at all with secondary
treated sewage.
Page 10 Last paragraph-second sentence. There is serious doubt in
the minds of local scientists about the comprehensiveness of the
planned monitoring program. Dr. John Phillips of Hopkins Marine
Station outlined his doubts in a letter dated Sept. 2nd to Ken
Jones of the California Regional Water Quality Control Board. Mem-
bers of this committee have observed that of the nine "fixed"
stations put down one month ago, one remains. In this case,"Fixed"
stations were tires filled with cement. The program also calls for
coring and taking samples without distinguishing rocky bottom from
sandy bottom. It takes no account of the effects other than those
in the immediate region of the outfall. In general, it appears to
fall short of comprehensive. An example of a comprehensive pro-
gram would be that for the Hyperion Treatment Plant in Southenn
California.
Last paragraph - fourth sentence. Reference 19 by Griggs
and Kiwalihas evidence that does not support this statement.
Page 11. Second
ph. Money is considered by many to be an
irreversible and irretrievable resource.
Page 12. Second paragraph - last sentence. Should extending ohe
outfall be considered as an alternative since it is said to cost
$6 millian which is more than tertiary treatment?
-4-
eitations
Brown, Robert B. 1971. Submerged sewage field off Southern Calif.i
A preliminary review of recent oceanographic
data. A paper given at the IEEE Conference on
Engineering in Ocean Environments. Sept 21-24,
1971 in San Diego.
Halstead, B.S. 1970. Toxicity of marine organisms caused by
pollutants. F.A.O. Technical Conference.
December, 1970.
Young, P.H. 1964. Some effects of sewer effluent on marine life
Calif. Fish and Game 50 (l)«33-41.
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HUDSON, PARR, KORAN,
LLOYD AND DENNIS
October 13, 1971
ENVIRONMENTAL PROTECTION AGENCY
Region IX
760 Market Street
San Francisco, California 94102
Attention: Paul De Falco, Jr.
Acting Regional Administrator
SUBJECT: OCEAN OUTFALL EXTENSION PROJECT
WPC CAL 468
Carmel Sanitary District, Carmel, California
GENTLEMEN:
This is in response to the proposed draft of the
Environmental Statement dated September 1971. For sake of
convenience I hereby incorporate by reference that certain
brief on file with your office submitted earlier this year
covering my Committee's request for a public hearing on the
subject, which request I hereby restate today. Reference is
also made to the telegraphic appeal on file with your office
signed and submitted by a large number of concerned citizens
of this area, including but not limited to leading scientists
of The United States Naval Postgraduate School, Hopkins Marine
Station and representatives of the State of California from
Moss Landing.
My comments and questions follow:
1] Upon what statutory authority did your
agency file a joint impact statement with the
California State Water Resources Board?
LAW cmces
HUDSON, PARK, HORAN,
LLOYD AND DENNIS
I
Page 2 Response to Draft of Impact Statement 11/13/71
2] The statement is false and intentionally |
misleading in that the $868,000 study initiated j
by the Association of Monterey Bay Area Govern- ',
ments does not undertake a comprehensive study i
of Carmel Bay nor does it, as the draft suggests |
"include oceanographic investigations related to
to marine disposal alternatives and will examine
!
alternatives for land applications, waste water '
reclamation and reuse options" of Carmel Bay.
The Director of the Association of Monterey Bay
Area Governments has made available the documen-
tation relating to this work. Out of some 35
sampling stations for the program scheduled to
last for ONE YEAR only, ONE sampling station is
the only investigative unit slated for Carmel Bay .
3] The statement is false and intentionally ;
misleading wherein it states that the citizen's ;
law suit "was dismissed for lack of evidence that tHe
I
project would have a detrimental effect on the j
!
plaintiff's property". The suit was not dismissed ;
I
for this reason and is now on appeal to the Calif- I
ornia Appeallate Courts on procedural grounds. '
The Sarmel Sanitary District was specifically not- i
ified of this error as was your office. * I
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Page 3
Response to Draft of Impact Statement
11/13/11
LAVCVTICE3
HUDSON, PARK, HORAN,
LLOYD AND DENNIS
4] It is stated in the "SUMMARY" of the
draft statement that ,"The project is an interim
measure to relieve existing pollution problems and
is in part being funded by the Environmental
Protection Agency." Until our Citizens Committee
became active there was no discussion of the our-
fall line being an "interim measure". As late as
March 23, 1971 the District's bond prospectus
made no such mention. The communications from the
District since 1968 reflected the fact that the
outfall line was the permanant solution. The
stipulations of Mr. Mott of Parks and Recreation
have no legal binding effect on the district; the
easement granted by the State of California across
the Carmel River State Beach is a permanant
easement. Mr. Jerry Gilbert, Executive Secretary
of the California State Water Resources Board is
on record in his position that the installation is
a pennant structure and that the only change is
not tertiary treatment but a longer outfall.
5] The draft states that "The creation of a
waste plume approximately 100 feet long on its
main axis would represent an undesirable adverse
esthetic effect." A visible plume of this des-
LAW OmCES
HUDSON, PARR, HORAN,
LLOYD AND DENNIS
Page 4 Response to Draft of Impact Statement 11/13/71
cription would be a violation of the minimum
acceptable standards established by the Regional
Water Quality Control Board. Obviously such a
discharge is in the very waters frequented by
skin divers and those studying the new area
proposed for an extension of the Point Lobos
underwater reserve .
6] "Two methods of land disposal of treated
waste waters have been investigated by the
District" These so called investigations were done
at the instance of the writer of these comments.
The Board refused to have a public hearing to air
the objections to the validity of these studies.
The State of California promised to provide
assistance in the study of this by the citizen's
committee who raised funds for the purpose of
exploring these very proposals through independent
engineers.
'
CONCLUSION: This "bootstrapping" by the technician'
staff of the two agencies responsible for the
design and approval of its location points up the
apparent futility of attempting corrections by
citizen comments. The project is mow virtually
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Page 5 Response to Draft of Impact Statement 11/13/71
IDSON. MRK, HOBAN,
iOYD AND DENNIS
completed. The office, to which this response is
directed consumed some five months of construction
time before it was finally able to come out with
a statement that could be made public. The State
of California Water Resources Board failed to
comply with its own state laws requiring environ-
mental statements to be filed. This has inever
been made public for public scrutiny.
To compound the matter the United
States Army Corps of Engineers was officially
put on record by the writer that a public meeting
was demanded. This was promised and subseqnantly
ignored. The content of the Army permit makes it
obvious that the issuance of a permit should have
been deferred pending their filing an impact
statement yet it took four months before their
counsel replied to the demand of the writer that
the permit be suspended until these issues had
been resolved.
The writer respectfully requests that
a hearing be granted and that all files of the
agencies involved be made available for public
scrutiny. Bo do less is to make a farce out of the
word democracy. ^tr" THOMSON JAYHUDSON
\
W
-------
OCT1 9
STATE OF CALIFORNIA-RESOURCES AGENCY
RONALD REAGAN. Gover
DEPARTMENT OF PARKS AND RECREATION
District It, Operations Division
97n Garden Road
Monterey, California 93940
October 18, 1971
Mr. Paul DeFalco, Jr.
Acting Regional Administrator
Environmental Protection Agency
Region IX
760 Market Street
San Francisco, California 94102
Dear Mr. DeFalco:
The following are the comments on the draft environmental impact statement prepared by
your Agency on the ocean outfall extension project of the Carmel Sanitary District,
Carmel, California.
Before commenting on the draft itself, a few general statements seem to be in order:
1. The Environmental Impact Statement should have been prepared prior to the
construction stage of the project. The fact that the statement came so late
gave the concerned public the impression that the outfall was going ahead
regardless of the findings of the Environmental Impact Statement.
2. The determination to put the higher treated effluent farther into Carmel Bay
rather than into the surf zone was made in spite of an overwhelming concensus
by the scientific community. This group of scientists, specializing in the
marine environment, is on record that the least damage to the marine environment
would be done by putting the treated effluent into the surf zone.
3. There is an extremely important question that hasn't been answered in the
draft. Where and how is the sludge to be disposed of? This should be known
because it is part of the complete process.
The following are comments on the questions that are unanswered by the draft environ-
mental statement:
1. Keeping the treated effluent in the surf zone was not considered as an
alternative, (p ii)
2. The summary states that The principle environmental impact will be to lower
existing conditions of pollution near the shoreline in Carmel Bay". This
statement seems logical; however, there has been no oceanographic studies
made to support this prediction. In other places in the Monterey area where
pipes are 300' to 600' offshore there is on-shore contamination, (p ii)
3. Will the Environmental Protection Agency guarantee that only secondary treated
sewage will pass through the pipe? If not, who will? What are the penalties
if lesser treated effluent is passed through the outfall? (p 3)
Mr. Paul DeFalco, Jr.
-2-
October 18, 1971
4. The impact of this outfall on Point Lobos State Reserve has been minimized.
Here again no oceanographic studies have been made to support this prediction.
Evidence of some kind is needed in the report to support statements, (p 4)
5. The report states that the proposed discharged effluent could be expected to
have a beneficial effect on the Bay as compared to its present condition, (p 8)
"We know of no instance in which the overall effect of any large-scale waste
outfall is considered to be beneficial. Introducing any artificial changes
into a natural ecosystem which has maintained an ecological balance for eons
is indeed risky. Even as proper harvesting of our natural resources must be
based on considerable scientific data to prevent disastrous results, even more
so must the placement of a large ocean outfall be considered only after extensive
and exhaustive research, and examination of data pertinent to the problem.
Changes inflicted on the environment can be irreversible". Odemar, Wild,
Wilson "A Study of the Marine Environment" July, 1968.
6. The report states: "The presence of an unnatural influence upon the Bay such
as this waste water effluent discharge would impair the value of this particular
location as a scientific laboratory for the study of natural phenomena. While
existing development around" the watershed which drains to the Bay already
precludes the preservation of completely natural conditions, the presence of
this waste water discharge causes a further departure from the desired natural
condition in the isolated area of the waste discharge", (p 8)
This conclusion should be sufficient to eliminate an ocean outfall as a means of
effluent disposal even on an interim basis in this particularly sensitive and
bountiful area.
7. The report states that this outfall is a short term, interim solution (p 9).
What time period is contemplated by the Carmel Sewer District for this
interim period?
The items enumerated above were of main concern to this office.
asked is obtainable we would appreciate hearing from you.
Sine
If the information
Assistant Superintendent
District 4
CM:m
-------
NOV.3 'ii;r
DEPARTMENT OF THE ARMY
SOUTH PACIHC DIVISION, CORPS OF ENGINEERS
630 Sansome Street Room 1216
San Francisco, California 94111
I MPLV ftCFKR TO
SPDPD-R
2 November 1971
Mr. Paul Do Falco, Jr.
Regional Administrator
EnvlromMntal Protection Agency
Region IX
760 Market Street
Sen Francisco, California 94102
Dear Mr. De Falco:
This le In response to your 13 September letter requesting our comments /
on the draft environmental impact statement on the ocean outfall exten-
sion project of the Carmel Sanitary District, Camel, California.
The San Francisco District, Corps of Engineers, issued a permit on 18
Jane 1970 to the Carmel Sanitary District, Carmel, California, for the
construction of this project. The applicant has complied with Special
Condition 3 of the permit which called for a certification under Section
21
-------
STATE Of CALIFORNIA— RESOURCES AGENCY
RONALD REAGAN, Govvr
DEPARTMENT OF PARKS AND RECREATION
P.O. BOX 2390
SACRAMENTO 99811
November 3, 1971
Mr. Paul De Falco, Jr.
Acting Regional Administrator
Environmental Protection Agency, Region IX
760 Market Street
San Francisco, California 94102
Dear Mr. De Falco:
Please refer to your letter of September 13, 1971, seeking our comments on
the draft environmental impact statement prepared by your Agency on the ocean
outfall extension project of the Carmel Sanitary District, Carmel, California.
Tour letter requested our comments by October 15, 1971; it has not been possible
for us to meet that date.
Our preliminary review of the draft statement indicates that it is satisfactory
from our standpoint, and the preparators are to be complimented on the objective
approach which they took to the various problems of the outfall. It is our
initial conclusion that the statement represents a fair analysis of the problems
which are attendant upon the construction of this outfall.
The draft statement has been circulated to members of my staff who have not had
an opportunity' to comment at this writing; should further comments be forthcoming
from them, those comments will be transmitted to you at a later date.
Sincerely,
K-l/11
/"
'William PeiuyMott,
Director /
-------
UNITED STATES
DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
BUREAU OF SPORT FISHERIES AND WILDLIFE
Reference: RB
730 N. E. PACIFIC STREET
P. O. BOX 3737
PORTLAND, OREGON 97208
November 8, 1971
Mr. Paul De Falco, Jr.
Acting Regional Administrator
Environmental Protection Agency
760 Market Street
San Francisco, California 94102
Attention: Mr. Fred Hoffman
Dear Mr. De Falco:
This is in response to your letter of September 13 to our Sacramento
Area office, Division of River Basin Studies, requesting the Bureau's
review of your draft environmental impact statement on "Ocean Outfall
Extension Project (WPC-CAL-468), Carmel Sanitary District, Carinel,
California." These comments are for your consideration in the review
process and are not intended to constitute this Bureau's formal analysis
under provisions of P. L. 91-190. We offer our compliments on your ex-
cellent presentation; however, we believe that a few points require
clarification.
The last sentence beginning on page 6 and the last paragraph beginning
on page 7 stress that while environmental damage could occur at the
diffuser site, it would be highly unlikely. Personnel of this Bureau,
in formulating our position on this project, did considerable literature
research on the effects of municipal sewage in the marine environment
and discussed the subject with many highly qualified individuals , in'
eluding personnel of your agency. We concluded that most scientists
believe municipal discharges probably have considerable impact on the
total marine environment. Changes of the marine environment at sewage
outfall sites have been documented many times over. The result often
is a gain in total biomass, but a reduction in species composition. It
is worth noting that those organisms most noticeably absent from sewage
discharge areas are often the same organisms that are most desirable
fron a sport fisheries standpoint. Many biologists have recognized
biological alterations and probable degradation in the vicinity of
sewage outfalls but, as a result of many uncontrollable parameters
1971
and the lack of preproject studies and other problems, are unable to
relate such changes directly to the outfall in question. It is even
more difficult to determine to what degree particular constituents of
the discharge are responsible for change or damage. We believe that
there will be some detectable damage to the marine environment as a
result of this project and that the extent of that damage will require
both preproject and postproject study.
We suggest that the phrase "less than conclusive" be stricken from the
last sentence beginning on page 6 and that the last paragraph beginning
on page 7 be revised to show that although some damage probably will
occur, the extent of that damage will not be known until the monitoring
studies are completed.
Also, we believe that the third paragraph, page 11., is contradictory.
The first sentence points out that the outfall is an interim facility
which will be abandoned. The second sentence indicates that the out-
fall could be considered for long-term use. This should be clarified.
We again commend you on the general excellence of this statement.
Sincerely yours,
' JCW) rv. nmuv
/ Regional Director
-------
ED REINECKE
LIEUTENANT GOVERNOR
OFFICE OF
INTERGOVERNMENTAL
MANAGEMENT
MOO TENTH STREET
jifctte of California
LIEUTENANT GOVERNOR'S OFFICE
SACRAMENTO 0B014
December 7, 1971
Mr. Paul De Falco
760 Market Street
San Francisco, California 94102
Dear Mr.. De Falco:
SUBJECT: SCH 71092009 - Carmel Ocean Outfall Extension
The above listed project was received in this office and dis-
seminated to various State departments for review. The
following comments were generated by the Department of Fish
and Game, the Department of Parks and Recreation, State Lands
Division, State Water Resources Control Board and the Office
of Planning and Research and cleared through the Agency secretary:
1)Department of Fish and Game
"In accordance with agency guidelines, here are our comments
and recommendations on this subject.
In summary, this impact statement does not assess in adequate
detail the potential impact of the action proposed. All
alternatives have not been explored. Clarification is
needed as to whether the project is interim, permanent,
or indefinite. In view of the considerable amount of
public money and local concern about this project, the
Environmental Impact Statement should be redrafted taking
into account our detailed review.
Our detailed review lists the page numbers and section of
the Statement along with comments, as follows:
Page ii - The Description of Action section clearly enun-
ciates this project as an "interim measure." We agree
with this concept and it was part of our understanding
when we concurred with the issuance of the U. S. Army
Corps of Engineers permit for construction of the outfall.
In the "Summary of Impact and Effects" the impact of
diffused waste of reduced salinity and other waste com-
ponents on the marine community in the vicinity of
the diffuser is ignored. We view the placement of outfall
locations in kelp-bed communities as detrimental to areas
Mr. Paul De Falco
Page 2
December 7, 1971
of biological significance. We believe that this delicate
marine community, which is dependent on a well-buffered
marine environment, may not withstand the lowered salin-
ities, chlorine, herbicides, and other unidentified constituents
associated with secondary treated domestic wastes. We hold
this view whether the discharge outfall is located within
the arbitrary boundaries of an underwater Reserve of the
California State Park System or not.
We are not opposed to the strategic placement of outfalls
in the marine environment to disperse well-treated wastes.
However, there are locations that contain unique complex
assemblanges of marine life that should not be used for
diffusion of even well-treated wastes. Carmel Bay is an
example of this.
Under the Alternatives Considered, an alternative for an
interim solution not considered was upgrading the waste
treatment to a level that would protect beneficial uses
without moving the discharge point location. Since newly
constructed outfall is an interim measure of protection,
we believe in. future cases such as this one, the concept
of upgrading treatment with eventual facilities to reclaim
wastewater for re-injection to ground water reserves
should be explored prior to extending an outfall. Further
examination of groundwater recharge needs in Carmel Valley
may reveal that wastewater reclamation is the best
possible alternative for the Carmel Sanitary District's
waste treatment operation.
Page 2 - The Statement discusses the programs to eliminate
pollutional effects of the present discharge. However,
the Statement limits itself to the ocean outfall extension
project and apparently ignores the improved activated
sludge (secondary treatment) process. We understand the
Statement is limited in this way from a funding standpoint,
but it is logical to consider both improved treatment
facilities and the changed outfall location when describ-
ing the environmental impact of this project. An examination
of the improved treatment may reveal, that as an interim
procedure, the extension of the outfall would not have
been necessary if the discharge to Carmel Bay is to be
ultimately terminated as indicated by the Statement and the
Corps permit for the outfall.
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Mr. Paul De Falco
Page 3
December 7, 1971
Page 3 - The diffuser nozzles are described as extending
three feet above the discharge line and discharging
horizontally. Attached to our comments is a survey
conducted by our Department in 1970 describing the marine
resources in the immediate area of the proposed diffuser
line. The statement fails to discuss the impact of the
diffusion of the waste upon these resources. We are espec-
ially concerned that the intrusion of a low-salinity chlorinated
effluent into this area will adversely affect these resources.
This possibility should be discussed in the Statement.
Based on the organisms listed in our survey, we believe
there will be an adverse effect on these resources in the
immediate area of the diffuser.
Further on page 3, it is indicated that the Corps of Engineers
permit was granted subject to the Environmental Protection
Agency condition that only waste with secondary treatment
would be conveyed through the outfall extension. Recent
discussions with other agencies reveal that the District
now wishes to discharge primary treated wastes through the
outfall prior to completion of its secondary treatment plant.
If this exception to the condition of the permit is to be
allowed, then its implications on environmental impact
should be discussed in the Statement. Also, the entire
project may have to be reviewed by concerned agencies
through the Corps permit process in order to clarify this
matter.
Pages 4-8 - Probable Impact of the Project on the Environment
The statements on page 5 imply that biological damage created
by the present discharge would be eliminated. In our view,
the project merely transfers the area of damage from a
surf zone to a more delicate marine ecosystem. The attached
list of species from our survey along the proposed diffuser
line substantiates this.
On Page 5, it is stated that Macrocystis sp. is an annual
plant. It is a perennial and not an annual.
With regard to protection of beneficial uses along the
shoreline and in the Point Lobos Reserve (presumably
including the marine life of the area), the Statement
Mr. De Falco
Page 4
December 7, 1971
misses the point in that beneficial uses are to be protected
in all waters of Carmel Bay, including those in the immediate
area of dispersion. As stated in the Summary Section, we
believe that operation of the proposed diffuser line will
have adverse effects on marine resources in the immediate
vicinity of the. discharge. However, even though this
particular engineering approach has this shortcoming, we
are agreeable to it on an interim basis in the interest of
allowing the Carmel Sanitary District to plan for an
effective permanent long-range solution to the problem.
On Page 6 of the report, it cites giant kelp (Macrocystis
pyrifera) as the most significant species of marine life
found Tn the vicinity of the proposed discharge. This is
misleading, since it is the entire assemblage of the kelp
bed community including the encrusting red algaes, fishes,
tunicates, and other species that has to be protected from
the discharge. While it is true that the large brown
algae (Macrocystis sp.) may be the dominant feature of
the community, it is conceivable that the discharge will
harm other species of the community without affecting this
algae.
The Statement implies that adverse effects of sewage discharged
to colder ocean water is less detrimental than that discharged
to warmer waters. Further, it is implied that certain
benefits to the sea otter food chain may be derived from the
extra nutrient burden of the domestic sewage causing an
unnatural abundance of sea urchins. This conclusion is
highly questionable. It is the variety and abundance of
marine life that is to be protected, along with the direct
human use of these resources. We are not in favor of
manipulating the production of certain marine species through
the use of waste discharge in this area.
We agree with the point the Statement makes on page 6 about
no detailed studies being made to determine precise effects
of these waste discharges on biotic communities.
It is implied on page 7 that there are fewer sea otters in
Southern California to use the abundant urchin populations
around the large municipal marine outfalls. According to
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Mr. De Falco
Page 5
December 7, 1971
our annual census surveys, there are no sea otters in
Southern California waters.
Also, on page 7, it is concluded that the degree of treatment
and dispersion achieved by the project will prevent signif-
icant effects on marine resources in Carmel Bay. In view
of the previous statement limiting consideration of
environmental impact to the outfall only, we are surprised
to see the reference to the improved degree of treatment.
However, with regard to prevention of "significant effects"
it is our position that there should be no adverse effects
from this discharge on the marine resources of Carmel Bay.
The conclusion reported on pages 7 and 8 that no detectable
effect will occur to marine resources other than from
construction is not an informed one. The report has entirely
ignored consideration of the impact from the diffusion of
wastes from ten diffuser ports upon a delicate kelp bed
community in the immediate vicinity of the diffuser port
line. Assurance should be given that the monitoring study
will be designed to take precise measurements of community
response in the immediate vicinity of the diffuser ports.
Page 8 - Probable Adverse Effects Which Cannot Be Avoided
This section states that the waste plume, approximately 100
feet long on the main axis of the diffuser line, would be
limited to an indescribable esthetic effect. This is not
true. It is probable that the marine community in this
area will be damaged by the diffusion of waste in the immed-
iate area of discharge. Low salinity, dilute chlorine,
herbicides and other constituents of the treated waste will
be causitive factors for these adverse effects. The last
paragraph admits that the influence of the waste will impair
this area as a "scientific laboratory for the study of
natural phenomena." This is a polite way of saying the
waste will upset the natural marine resources community
by eliminating or reducing marine organisms in the immediate
vicinity of the discharge.
We object to the parallel drawn between changes in the
watershed causing unnatural conditions in the Bay to those
Mr. De Falco
Page 6
December 7, 1971
caused by the diffusion of waste. This concept seems to
imply that the two effects are the same in degree, which
is not so. If certain changes in the watershed are causing
detectable adverse effects on the Bay, we would favor changing
these practices as much as possible to eliminate these
adverse effects.
Pages 8-10 - Alternatives to the Proposed Action
As pointed out at the beginning of our comment, the alterna-
tive of upgrading treatment without changing the point of
discharge was not considered. Indeed, in view of the
stated intent of the interim nature of future discharge to
Carmel Bay, we feel examination of this alternative could
have saved the project money spent on the outfall.
We cannot concur with the concept that reclaimed waste water
has to be directly reused for industrial or other direct
consumptive purposes in order to be a feasible alternative
to ocean disposal. The groundwater table in the Carmel
Valley is water-short. Recharge of reclaimed waste water
would appear to be a suitable alternative to construction
of more water storage dams in the upper Carmel Valley.
Much steelhead habitat has been sacrificed in order to
provide water storage and groundwater recharge to water-
short areas. It seems wasteful to continue this practice
while potentially good reclaimed water is wasted to the
ocean. Therefore, the report should state that the alter-
native of reclaiming the District's wastewater for groundwater
recharge to potentially water-short areas will be examined.
Also, the report should note that the ocean floor topography
in Carmel Bay is very steep and would probably preclude
extension of the outfall to offshore areas as a feasible
alternative.
Page 10-11 - Short-Term Use vs. Long-Term Productivity
We question the concept that effects must be arbitrarily
"significant" in order for this interim project to be
terminated. We have viewed this project as interim from
the start. Our concurrence with the Corps permit was based
on the premise that the discharge to Carmel Bay through this
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Mr. De Falco
Page 7
December 7, 1971
outfall was an interim measure. In our estimation, there
was no question of further studies having to provide addi-
tional information in order to terminate the operation
of this project. We are in concurrence with the California
State Department of Parks and Recreation that the outfall
project is an interim one and will be abandoned when
suitable long-range plans for final disposition of the
District's wastes are formulated and implemented.
Page 11-13 - Local Objections to the Project
This section states that a comprehensive monitoring program
is to be carried out by the discharger to detect damage
to marine resources. Further, the results of the program
would determine whether the project was interim or would
be allowed to continue on a permanent basis.
As stated before, our understanding of the project was that
it was an interim solution to an immediate problem. The
monitoring program was designed to merely detect gross
pollution problems centering on public health matters during
the interim period. Biological data gathering was also
designed to detect malfunctions of the system during the
interim period. There was no question that the entire
program including use of the outfall was interim and would
be terminated within two to five years. Now, it is proposed
that the already approved monitoring program be used as a
basis to allow the discharge to continue indefinitely.
The proposed monitoring program received only a cursory
review by most State agencies based on the understanding that
the entire program was interim only. Our review of the pro-
gram did not receive a required detailed examination. There
were no inter-agency meetings between all interested agencies
to discuss the details of the program or its intent.
If the project is not interim and the continuance of the
discharge to Carmel Bay is to be based on the monitoring
program results, then the program has to be redesigned to
fit these new conditions. The present monitoring program is
inadequate to detect damage to marine resources from the
chronic discharge of wastes receiving a reliable secondary
Mr. De Falco
Page 8
December 7, 1971
treatment with chlorination. Transects and sampling
locations are now spaced to detect gross pollution effects
only over a wide area. There is no provision to detect
changes in the immediate vicinity of the outfall. At a
minimum, part of the monitoring program should contain
stations on the rocky substrate along the outfall diffuser
line. The program should provide for a minimum sampling
of these stations for one year prior to the discharge of
effluent through the line. This will provide a minimum
of baseline data upon which to base analysis of future
sampling after the line is in operation. Further, the
monitoring program should be conducted by the best local
marine biologist experts available in the area. In our
view, our Department or Hopkins Marine Station personnel
are the best qualified to perform this task.
Therefore, we propose that a detailed review of the mon-
itoring program be made by concerned State, Federal, and
local agencies in the interest of designing a program that
will detect actual effects of the effluent in the vicinity
of the discharge.
The following agencies should be included in this review:
U. S. Environmental Protection Agency
U. S. Fish and Wildlife Service
California State Water Resources Control Board
California Central Coastal Regional Water Quality
Control Board
California Department of Fish and Game
California Department of Parks and Recreation
California Department of Public Health
Hopkins Marine Station
In conclusion, the Environmental Impact Statement should
be redrafted, taking into account our comment on the need
for expansion and clarification of certain sections of the
draft. Also, the monitoring program should be revised,
keeping within the intent of the overall program. Also,
we suggest that a qualified marine biologist familiar with
the marine resources of the Carmel area by employed to
rewrite sections of the Statement relating to biological
aspects of these resources.
We are available for any questions concerning our comments.
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Mr. De Falco
Page 9
December 7, 1971
For further information regarding these comments, please contact
Mr. E. C. Fullerton, Department of Fish and Game, 1416 Ninth
Street, Sacramento 95814 (916) 445-5250.
2)State Water Resources Control Board
"The State Water Resources Control Board is a co-author
of the subject environmental impact statement. Therefore,
it is inappropriate for this office to comment on the EIS.
We shall consider comments from other agencies when final-
izing the above statement."
For further information regarding these comments, please contact
Mr. Paul R. Bonderson, State Water Resources Control Board,
1416 Ninth Street, Sacramento 95814 (916) 445-7971.
3) Department of Parks and Recreation
"The granting of an easement across Carmel River State
Beach indicates that the Department of Parks and Recreation
recognizes that an immediate and critical sewage treatment
problem exists in this area. The department also recog-
nizes that a permanent solution for the treatment and
discharge of sewage from this district will require research,
analysis and study over a period of time. However, it must
be restated that the easement was granted in good faith
and under restricting conditions, as an interim solution
only, to resolve the existing pollution problem.
With the beach easement the department established two
conditions which are included in the State and Federal
grant to the Sanitary District. These conditions require
the district to thoroughly monitor the water movements and
cause and effect of the effluent being discharged in the
bay and to reach a satisfactory treatment solution based
on the monitoring data by February 1, 1974. In relation
to these conditions we have reviewed the monitoring program,
dated July 22, 1971, and prepared by the California Regional
Water Quality Control Board, Central Coast Region. We
also have discussed the program with a representative of
the Division of Water Quality, State Water Resources Control
Mr. De Falco
Page 10
December 7, 1971
Board. It is our conclusion that the monitoring program
as presented will not adequately satisfy the department's
conditions of the easement. Major deficiencies in the
program revolve around the following points:
1. The program will not provide adequate water current
sampling to determine the cause and effect of the
true underwater change. This conclusion was
reached since the program calls for only one
current meter. Additional current meters should
be placed in the bay since limited data on water
movement in this area is available.
2. Core samples, according to the plan are to be
taken regularly from points along established
transects. In place of this a more comprehensive
ocean bottom sampling program should include a
random sampling selected from all accessible
underwater areas of the entire bay. This would
result in an overall picture of the effluents
effect on the entire underwater ecosystem.
This Department has recently published the California
Coastline Preservation and Recreation Plan which indicates
that the Point Lobos State Reserve, Carmel River State
Beach and all of the underwater area of Carmel Bay incor-
porate unique and outstanding natural resource values which
should be preserved and protected. In accordance with
these findings we are determined to safeguard the environ-
mental quality of this area. There is only one ultimate
sewage treatment solution which we can support in this area,
and that is the complete termination of all effluent dis-
charge in Carmel Bay."
For further information regarding this comment, please contact
Mr. William Penn Mott, Jr., Department of Parks and Recreation,
1416 Ninth Street, Sacramento 95814 (916) 445-2358.
4)State Lands Division
"1. The five-foot wide trench will traverse an area of
sand. It is possible that the angle of the trench sides
in sand will be much less than a one-to-one slope; thus,
the area of temporary disturbance may be larger than 3000
square feet.
2. What will become of the sand and rock excavated while
pipe laying is in progress? Assuming there will be some
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Mr. De Falco
Page 11
December 7, 1971
backfill, what will be done with the material that is
displaced by the pipe and concrete? If the trench is to
be backfilled entirely with concrete the statement should
be clearer.
3. The alternatives of different lengths and locations
for the outfall line, except that of a longer pipe, were
not discussed. Do current elements within the Bay, together
with peak discharge times and quantities, effluent away
from the beach and the Reserve?
4. Under "Irreversible. . .Commitments" it may be an
unwarranted assumption, and thus a false assurance, that
the regional disposal system ultimately adopted will result
in abandonment of the use of the proposed outfall. Similarly
assurances that the aquatic resources will be unaffected by
the regional system appear to be premature.
Thank you for the opportunity to comment."
For further information regarding this comment, please contact
Mr. R. S. Golden, State Lands Division, 1020 12th Street,
Second Floor, Sacramento, 95814 (916) 445-5303.
5)Office of Planning and Research
"The Environmental Impact Statement, as prepared by the
Environmental Protection Agency, does not adequately assess
the issue of population growth and distribution in the
Carmel area. It is the population growth and consequent
urban development in the area that has created a situation
which is threatening the quality of the environment. The
uniqueness of this environment, which is of statewide
significance, has brought esthetic popularity and economic
viability to the residents of this area. These residents
are seeking to establish population and land use policies.
An example of an action that has been taken in a nearby
county is the adoption of "Urban Development Policies"
by the City of San Jose on October 19, 1970. One of the
recommendations that states City Responsibility to Property
Owners and Citizens contains the following:
'Public facilities shape the physical, social, and
economic form of the city. The ability to extend or
refuse to extend utilities or services is a proper
tool to use in guiding urban development.'
The environmental statement for the Carmel Ocean Outfall
Extension Project deliberately sidesteps this issue and
Mr. De Falco
Page 12
December 7, 1971
does not include a discussion on the topic that would seem
pertinent to the implementation of this project.
The quality of the environment in the Carmel area depends,
in large part, upon the improvement and maintenance of the
water quality of the drainage system and the receiving
ocean waters. The proposed expansion of the Point Lobos
Underwater Preserve would help to protect the marine
portion of the environment, but the discharge of treated
waste waters into the Carmel Bay, even on an interim basis,
will undoubtedly change the ecology of this area.
Realizing the need to upgrade the treatment of effluent
from the Carmel Sanitary District to secondary or tertiary
quality and realizing the need for complete termination of
all discharge into Carmel Bay, the following is recommended:
1. Some formal guarantee that the outfall extension
will only be an "interim" solution and that all
effluent discharge into Carmel Bay will cease by
1974.
2. An effective and continuing monitoring system in
the Carmel River and Bay, conducted by State Fish
and Game biologists, to assure the preservation
of the natural quality of the marine ecology.
3. A thorough investigation of all alternative solu-
tions to assure that the effluent will be completely
recycled and used for groundwater recharge, ag-
ricultural irrigation, park use, or some similar
use that will not endanger the fragile environment
of this area.
4. The development of population and land use policies
for the Carmel area that are comprehensive in
their approach and serve to guide the development
of utilities so that they are consistent with the
maintenance or enhancement of environmental quality.
We are in agreement with the statements made by the
Departments of Fish and Game and Parks and Recreation with
regard to the Environmental Impact Statement on the Carmel
Outfall Extension."
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Mr. De Falco
Page 13
December 7, 1971
For further information on this comment, please contact Mr.
John Passerello, Office of Planning and Research, 1400 10th
Street, Sacramento 95814 (916) 445-4831.
These comments were aimed at assuring that your project is
coordinated at all levels of government and to insure a strong
application to the funding agency. The State Clearinghouse
would appreciate Unowledge of any communications that you
might have with the commenting departments .
We request that you use the State Clearinghouse number assigned
to your project on the cover page of your application, since
this number will be used by the funding agency when the State
Clearinghouse is notified of the awarding of your grant.
Sincerely,
MARK E. BRIGGS, Assist
Office of Intergovernmental
Management/State Clearinghouse
MEB:jan
Leslie L. Dolittle, AMBAG .
E. C. Fullerton, Fish and Game
Paul R. Bonderson, SWRCB
William Penn Mott, Jr., Parks and Recreation
R. S. Golden, State Lands Division
John Passerello, OPR
Attachment
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SIERRA CLUB ~ VENTANA CHAPTER
"W 10 2 1(1 PM '71° BOX S<"6'- CAIIMEK, CALIFORNIA Ol'.l^l
Dece.-.oer 1--,
Mr. Paul OeFalco
760 ilarket Street
San Francisco, Ca. 9^102
Subject - WPC - GAL - 463
Caru^l Ocean Outfall
Dear Sir,
Ventana Chapter, Sierra Club, is deeply interested in
protection of the natural values possessed by GaK.;el Bay. '.ve
are interested in preservation of t.ie underwater biota as v.-ell as
protection of shore line.
Because of this interest we ha ve examined Draft En-
vironmental Statement re Camel Outfall jlxtension with ^reat in-
terest.
It is widely recognized that Car..iel Bay contains spe-
cial and unique attributes wnica deserve special protection. It
contains an underwater area alongside Point Lobos Reserve r.m:
classified as an uoaeruater reserve ar*» Car.;el Bay itself is un-
der consideration for classification by the De;t. of par.-:s _; Re-
creation as a Reserve. The vaters a.-.d biota of t.ie 2ay are as
yet relatively unspoiled. For tnis reason the ai-es. is valuable
for scientific study as vrell as for Tiewina £.:•& -photo:.raphi.-.j.
Jacques Cousteau has said it is a fragile area and unless ..ro-
tected will be lost.
•These are tie reasons ve -.ir^entiy £'^_££t t,-.at t.ie
present and proposed outfalls into the Bay 'OB vie-.:=c :.£. a.-: "s.n
interim solution". ",."e trust t..at the t::o parsers.;.-.s at t.ic.- joc-
toa of page 3 of above .;a.ieu Drafi 'x cor.tai.-.ai i.-. 0..= i'i.L;.i re-
port.
Tl;e rev: outfall -J.y be .•^ce3j£.r. i£ a -..cr-t til-.: ..ex-
sure or as a Safety valve for occasional u;e -_t £.._:..:.£.'.!. i.-.ouli
be cade on the necessity for alwer.u.tive -'ii,:;£El ..Sw:..'Ji ti "_«
adopted as soo/i as poiiible.
December 21, 1971
THE ASSISTANT SECRETARY OF COMMERCE
Washington. D.C. 2O23O
«"
Mr. Paul DeFalco, Jr.
Acting Regional Administrator
Environmental Protection Agency
760 Market Street
San Francisco, California 94102
Dear Mr. DeFalco:
^^ ^. ***
> m
00 S8
z- 55
_3 =
We have reviewed your draft environmental statement on
the Ocean Outfall Extension Project (WPC-CAL-468),
Carmel Sanitary District, Carmel, California.
The draft statement indicates the ocean outfall sewer
extension is an interim measure to relieve existing
pollution problems and that the principal environmental
impact will be to lower existing conditions of pollution
near the shore line in Carmel Bay. We note also that
long-range alternate solutions to this problem are
currently under study by a regional water quality plan-
ning agency with State and Federal financial support.
There will be some damage to marine life during construc-
tion of the outfall line. However, it is expected that
reestablishment of near natural conditions would occur
once construction of the line is completed. We have no
serious adverse comments on the draft statement.
We appreciate this opportunity to review this statement
on the proposed project.
Sincerely,
-Sidney R.I Gal
Deputy Assistant Secretary
for Environmental Affairs
Enclosure
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Appendix C
Response to comments not included in the text of the Statement
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Comments by the U. S. Geological Survey
Comment: "Will recent zoning decisions in the Carmel area,
which appear to make increased residential and
commercial development a certainty, have appreciable
effect on the quality and quantity of waste waters
discharged to the Carmel plant? If so, were these
anticipated changes examined during assessment of
feasibilities for other disposal alternatives?"
Response: See the section entitled Background and Description
of the Project for anticipated 1985 flows.All
anticipated changes in quantity and quality of
waste water will be considered in determining the
ultimate method of handling Carmel's waste water
problems.
Comments by the Army Corps of Engineers
Comment: "The statement does not mention the possibility
that part of the surfacing sewage field would be
released to the atmosphere and transported shoreward
as an aerosol through white caps and breaking waves
action. This could result in a significant public
health problem and should be evaluated in the
statement."
Response: There is no known public health problem resulting
from aerosols from the present outfall which dis-
charges directly into the surf zone. Although this
potential hazard does exist, it should be mitigated
by the higher degree of treatment and discharge to
deeper waters. It is possible that some of the
surfacing effluent plume may be released to the
atmosphere as an aerosol and transported shoreward.
There is no known evidence that aerosols from similar
outfalls.have ever created a public health problem.
Comment by the California Department of Parks and Recreation.
Comments: "Will the Environmental Protection Agency guarantee
that only secondary treated sewage will pass through
the pipe? If not, who will? What are the penalties
if lesser treated effluent is passed through the
outfall?"
Response: The Environmental Protection Agency reaffirms its
commitment to the condition on the Army Corps of
Engineers permit that only secondary treated
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effluent be discharged from the outfall. If
lesser treated effluent is discharged, the Corps of
Engineers may issue a Cease and Desist Order.
Comment: "The report states that the proposed discharged
effluent could be expected to have a beneficial
effect on the Bay as compared to its present
condition, (p. 8) 'We know of no instance in which
the overall effect of any large-scale waste outfall
is considered to be beneficial.1"
Response: The present condition referred to here is the
pollution problem created by the existing outfall.
Comments by the Monterey Committee for Environmental Information
Comment: "Will the E.P.A. guarantee that only secondary
treated sewage will pass through the pipe? If not,
who will?"
Response: See Comment and Response of California Department
of Parks and Recreation.
Comments by Hudson, Farr, Koran, Lloyd and Dennis
Comment: "Upon what statutory authority did your agency file
a joint impact statement with the California State
Water Resources Board?"
Response: Since the Federal and State Laws require similar
environmental statements as described on page £(_
and since there is no legal impediment to Federal-
State cooperation, it was decided to file a joint
statement.
Comment: "The statement is false and intentionally misleading
in that the $868,000 study initiated by the
Association of Monterey Bay Area Governments does
not undertake a comprehensive study of Carmel Bay
nor does it, as the draft suggests ' include
oceanographic investigations related to the marine
disposal alternatives and will examine alternatives
for land applications, waste water reclamation
and reuse options' of Carmel Bay."
Response: The statement does not claim that the AMBAG study
will undertake a comprehensive study of Carmel Bay.
However, the combination of the AMBAG study, the
District's receiving water monitoring program
-------
described in Appendix A, the County Public Health
Department's ongoing monitoring program, and the
studies being done by the Hopkins Marine Station
and by Monterey Peninsula College, will comprise a
comprehensive study of Carmel Bay.
The AMBAG study will indeed "include oceanographic
investigations related to marine disposal alternatives
and will examine alternatives for land applications,
waste water reclamation and reuse options." .
Comment: "The statement is false and intentionally misleading
wherein it states,that the citizen's law suit 'was
dismissed for lack of evidence that the project
would have a detrimental effect on the plaintiff's
property.'"
Response: The Superior Court order in the case of Hudson vs
Dibble is attached.
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IN TliE SUPERIOR COURT OF TliE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF MONTEREY
DISTRICT, at al.,
U
Defendants.
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ilOMbON J. HUDSON, )
Plaintiff, ) No. 68487
VS. ) ORDER DENYING INJUNCTION
EDWARD F. DIBBLE, CARMEL SANITARY ) AND SUSTAINING DEMURRER
, ,Tne Court finds that plaintiff is not entitled to
injunctive relief in this case for the following reasons:
1. That plaintiff has been provided an administrative
forum under Sections 13263, 13301, 13302, and 13320 of the Water
Code. A judicial review by mandate is ^rovidoa by Section 13330.
It does not appear that plaintiff has alleged or proved that he
has exhausted his administrative remedies and there;ore has failed
to satisfy this condition precedent for action in the Superior
Court. (Triangle Ranch Inc. vs. Union Oil Co., 135 Cal. App.
2d 428, 438).
2. Plaintiff has produced no satisfactory evidence
that the extension of the outflow line for an additional four
hundred feet into Carmol Bay will have a detrimental effect on
his property lying on the southerly shore of that Bay. It appears
that the defendants have made a study of currents and are
continuing to make such study and have satisfied themselves that
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tho proposed construction is adequate to protect the beneficial
usos of the water in this aroa. Finally the new outfall will
have the benefit of a diffuscr. Tho uncontrovortad testimony
9 is that this will servo to spread the effluent over a far
10 greater arc a than tho present open end pipe and therefore
11 constitute an improvement over the present condition. The
12 Court therefore finds that plaintiff has not established by a
13 preponderance of the ovidonco that the threatened action of
L4 defendants will injure plaintiffs
15 Injunction is a harsh remedy and in this case by reason
16 of increase in costs of construction if that is held in abeyance
for a considerable time damages might well run up to four hundred
thousand dollars. Whether plaintiff would be benefited or
donmgud by tha proposed construction ia open to debate; but in
20 any ovunt plaintiff made no effort to sot a monetary value on
21 tho damages he thinks ho wight suffer.
22 For the foregoing reasons the temporary restraining
23 order is dissolved and the application for preliminary injunction
24 is denied.
P fi
The general domurror of defendants is sustained on
tho ground that plaintiff has failed to exhaust his administrative
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remedies .
28 It is noted that plaintiff has stricken the first
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sentence of paragraph 5 of the complaint and alii allegations upon
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which to base a prayer for monetary relief, therefore/ tho
(iomurror for uncertainty has become moot.
Plaintiff is granted twenty days in which to amend
his complaint* ;•
Datedi /April 19, 1971,
STANLEY LAWSON
Judge of the Superior Court
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ENTERED
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ERNEST A. MAGGIN1 j^ j IQ 3j $,{27!
PEPUTYfW?/*• /_, ...««.• .-I
ERNtbTA. ;;;-;••' ,t
bOU&i i :-."y-rtlS.^c-'
IN THE SUPERIOR COURT OF THE STATE OP CALIFORNIA
IN AND FOR THE COUNTY OF MONTEREY
THOMSON J. HUDSON,
Plaintiff,
vs.
EDWARD F. DIBBLE, et al.,
Defendants
No. 68487
ORDER DISMISSING ACTION
The application of defendants CARMEL SANITARY DISTRICT
and CARMEL SANITARY DISTRICT BOARD OF DIRECTORS for an Order
Dismissing the above entitled action pursuant to Code of Civil
Procedure Section 581.3 came on regularly for hearing before the
Court on June 7 , 1971, and the Court having considered the
declaration and application of JEREMIAH J. LYNCH, Attorney for sai
defendants, and it appearing to the satisfaction of the Court
that plaintiff THOMSON J. HUDSON has failed to amend his complaint
herein within the time allowed by Order of this Court entered on
April 19, 1971, sustaining defendants' demurrer to said complaint
with leave to amend within 20 days after notice;
IT IS HEREBY ORDERED, ADJUDGED and DECREED that the
above entitled action be dismissed and that plaintiff take nothing
by said action.
DATED;_ £L~«~7,
L/ jz%?%^// * _-_,
^&
NOTICE OF ENTRY Of JlJOGMiiNy
MAIU3D BY CLBRX OM \2 J It / /(
ir GPO W1.190
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Jt
Carmel Bay
Diffuser 24*
Section
Mean Sea Level
Connect to
(existing pipe
Existing 14
outfall sewer
I
CARMEL RIVER
STATE BEACH
PLAN
2 minimun cover
=• TO beginlng of
diffuser
SECTION
Scenic / EXISTING
Pt. ^ CARMEL
SEWAGE TREATMENT
A Carmel \ PLANT
Bay
PROPOSED
OUTFALL
EXISTING
OUTFALL
SEWER
LOCATION
MAP
HORIZONTAL
VERTICAL
50
-MHHW-2A
-MLLW-2.5
200 100
200
Scale in Feet
PROPOSED OUTFALL SEWER
IN CARMEL BAY
SOUTH OF CARMEL RIVER
COUNTY of MONTEREY
CALIFORNIA
ENVIRONMENTAL PROTECTION AGENCY
REGION IX
SAN FRANCISCO. CALIFORNIA
Scale in Feet
(U.S.C8GS Chart No. 3476)
Figure 1.
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Man iereu "Bay
PROPOSED PT. L060S MARINE t
RESERVE & UNDERWATER PARKl
Figure 3
MONTEREY BAY REGION & LOCATION
OF PROPOSED POINT LOBOS MARINE RESERVE AND UNDERWATER PARK
f \9in7
POINT LOIOS STATE RESERVF
PROPOSED MARINE RESERVE ft UNDER WATER PARK
OtpOu In tfthoau tt HLLHf
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