San Diego Regional Water Quality Board                                                       Dec 11, 2019
San Diego Region
2375 Northside Drive, Suite100
San Diego, CA 92108
SanDiego@waterboards.ca.gov

Chairman Mr. David Gibson,

While I applaud the recent bi-partisan efforts to draft a multi-party Resolution regarding the request for Federal funding of TRV sewage issues, there are several elements in the specific language of the Resolution which are very concerning to local residents of the TRV and adjacent beach communities.

Our primary concern is with the proposed TRV stakeholder’s solution which presents a clear lack of compliance with the Clean Water Act of 1972; as the proposal does not address/require secondary treatment standards.

Additionally, the Alternative “D” option of the Resolution reads as such: “to intercept, divert, and treat in compliance with the Clean Water Act as much of the polluted flows from the Main Channel of the Tijuana River at the South Bay International Waste Water Treatment Plant as possible (currently estimated at 163 million gallons per day based on the unpermitted carrying capacity of the South Bay Ocean Outfall) and to discharge that treated effluent through the South Bay Ocean Outfall”  Increasing the SBOO discharge to over 100 mgd is not defendable science and certainly not proactive environmental stewardship.

Furthermore, the final draft Resolution also reads: “and to study, analyze, and assess the feasibility of constructing additional storage at a new 82 million gallon basin immediately downstream of the IBWC flood control channel as referenced in the NOA Matrix as Alternative D;”  The location of this proposal is directly adjacent to the Coral Gate neighborhood and previously drew severe ire of the residents as well.

In light of these serious shortcomings with the proposed TRV stakeholder’s solution, we ask that a NO Vote be cast on today’s Agenda Item No. 9.

Respectfully,

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