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HomeMy WebLinkAbout06. (Handout) Updated Legislative Matters Information and Correspondence Item 6. ,AVI CENTRAL SAN (Handout) CENTRAL CONTRA COSTA SANITARY DISTRICT April 18, 2019 TO: THE HONORABLE BOARD OF DIRECTORS VIA: ROGER S. BAILEY, GENERAL MANAGER FROM: EMILY BARNETT, COMMUNICATIONS AND INTERGOVENMENTAL RELATIONS MANAGER SUBJECT: UPDATED LEGISLATIVE MATTERS INFORMATION AND CORRESPONDENCE The following attachments are late breaking items relating to Legislative Matters Item No. 6 on the Agenda. 1. Central San Letter of Support for AB 1672 (Bloom), Wet Wipes Labeling to be heard in the Assembly Judiciary Committee 2. Central San designed Myths and Facts sheet for CASA for AB 1672 (Bloom), Wet Wipes Labeling 3. Coalition Letter Opposing SB 332 (Hertzberg) relating to Ocean Discharge requirements 4. Central San Letter in Opposition of SB 69 (Wiener) regarding denitrification Attachment 1 Central Contra Costa Sanitary District -Protectin-public hoalth and the envirownent 5079 Imhoff Place, Martinez, CA 94553-4392 PHONE: (925)228-9500 April 15 2019 FAX.- (925)335-7744 www.centralsan.org ROGER S.BAILEY General Manager The Honorable Mark Stone, Chair KENTON L,ortheDALM Counsel jthe District Assembly Judiciary Committee KAT/E YOUNG 1020 N Street, Room 104 Secretary ojthe District Sacramento, CA 95814 RE: AB 1672 (Bloom): Wet wipe labeling: Support Dear Chairman Stone: Central Contra Costa Sanitary District (Central San) is pleased to support AB 1672 (Bloom). Central San, established in 1946, provides wastewater collection and treatment services to nearly 500,000 residents and more than 3,000 businesses in the East San Francisco Bay Area. Within its 145 square mile service area, Central San operates a 54 million gallon-per- day capacity treatment plant, 18 pumping stations, over 1,500 miles of sewer lines, a household hazardous waste collection facility, and provides both commercial and residential recycled water programs. AB 1672 would establish labeling requirements and performance standards for wet wipes so that Californians will know whether a product can be discarded safely by their plumbing. In recent years, wet wipes have gained popularity as they're designed for a variety of daily household purposes, and some are advertised as "flushable," which encourages residents to dispose of wipes products generally by their toilet instead of in the trashcan. Because many wet wipes are not compatible with sewer systems and infrastructure, flushing these products results in their getting caught in pipes or accumulating with fats, oils, and grease and becoming larger obstructions that cause costly backups, or further down the sewer line, weaving together and creating giant rags which get stuck in pump systems and motors and damage expensive agency equipment. Furthermore, in order to de-clog mechanical equipment, our employees must regularly disassemble heavy machinery like pumps, grinders, and bar screens which are not necessarily designed to be readily taken apart. Unclogging rags involves reaching in to manually remove debris, either with hand tools or gloved hands. This puts workers in close contact with raw sewage, increasing the risk of exposure to pathogens, and also creates a risk for coming in contact with sharp debris that can entangle in the masses. Central San has been tackling wipes issues for several years within our infrastructure. Our active outreach program to help consumers make proper disposal choices consist of extensive labor-intensive work in outreach. Wet wipes have been an increasing problem for property owners, sewer systems paid for by the public, and the environment as they cause major damage to equipment, require labor to rectify the problem, and cause sanitary sewer overflows in neighborhood streets and local waterways. eRecycled Paper Central San's Support of AB 1672 (Bloom) April 16, 2019 Page 2 Central San and other wastewater agencies around the state are expending extensive labor and resources to properly maintain sewer systems and educate the public on wipes disposal, while wipes manufacturers continue to reap the benefits of sales without proper consumer education. AB 1672 would ensure wet wipes packaging clearly communicates whether the product can safely be discarded through a toilet, or will not break apart like toilet paper, and should not be flushed. This gives the consumer the information they need to make the correct disposal option. For these reasons, the Central San strongly supports AB 1672, and we respectfully request your"Aye" vote when the bill is heard before you. Sincerely, 1 n Roger S. Bailey I General Manager cc: Assemblymember Richard Bloom Members, Assembly Judiciary Committee Jessica Gauger, California Association of Sanitation Agencies Attachment 2 AB 1672 (Bloom): Labeling Requirements for Single-Use Disposable Wipes MYTHS & FACTS Sam MYTH: AB 1672 would ban the FACT: AB 1672 would not ban the sale of any product. AB 1672 would do 2 things: sale of flushable wipes in California. 1)Require clear and accurate labeling of wipes so consumers can easily distinguish between"flushable"and "non-flushable"wipes,and 2)Set needed technical standards for use of the term"flushable"that will protect public infrastructure,prevent sewage spills and safeguard water quality. MYTH: The standards set by AB FACT: The standards set by AB 1672 were created by an international group of technical experts with no conflict of 1672 are not scientifically based. The interest to ensure that sewer systems,rivers,streams,and the ocean are protected. The standards created by INDA/ standards created by INDA/EDANA, EDANA are simply not strict enough to protect sewer systems and were created by the very companies that want the wipes'industry associations, to maximize the sale of wipes. They have an inherent conflict of interest and do not have the mission of protecting are the ones that should be used to public health,environment or infrastructure.This contributes to sewer providers across the state,country,and determine what is"flushable." internationally experiencing massive wipes clogs causing sewer system issues and overflows. MYTH: Consumers need FACT:AB 1672 does not prevent any type + �4D flushable wipes to meet their basic of wipes from being sold for use in California. r i hygiene needs,especially those AB16729nl addresses the issue of how a consumers with particular health wipe should be labeled. Unless wipes meet ■ issues or other special needs. AB strict technical standards necessary to be 7...; 1672 would prevent them from "flushable;'they should be placed in the using these products. trashcan,not the toilet. MYTH: There is a lack of data to FACT: Sewage spills can have many .yi! show that sewage spills are caused different causes,and many spills are caused by flushable wipes. by multiple factors that occur together, r i Or such as presence of excess wipes,tree root intrusion,and accumulations of fat,oil and grease. In California,the Statewide Sanitary Sewer System Waste Discharge Requirements - ""X_ " F prohibits ALL sewage spills and requires that all spills be reported to the State. FACT:Public agencies have spent millions of dollars in public money installing screens and grinders to address wipes clogging their treatment plants,pumps,and pipes.Additionally,sanitation workers spend thousands of hours each year to clear and clean blockages in equipment. MYTH: Flushable wipes FACT: We agree that public education is critically important. However,consumer confusion is caused by the manufacturers are being blamed fact that many wipes are labeled as"flushable;'and more and more products are claiming to be safe to flush.The for a problem that they don't cause, proliferation of flushable wipes in the marketplace and the growing market penetration of this product has resulted which is really caused by consumer in the need for strict and objective technical standards.AB 1672 would address this need. misbehavior. Education of the FACT:Sewer districts around the state have engaged in outreach for campaigns well over a decade.Yet the industry public is the solution. has done little outreach,and is opposing AB 1672,which requires the most basic of consumer education--product labeling.Even with concerted public outreach by sewer agencies,wipes are still a problem. AB 1672 will provide enhanced public education to combat this problem. MYTH: Clogs are really caused FACT: Conserving water is the new standard for all Californians,which does reduce wastewater flows.This is all by Californians'conserving water, the more reason that items like wipes that don't break down quickly in the sewer system should not be flushed and reducing the amount of water in should be put in the trash can instead. sewer pipes—causing backups. CASA CALIFORNIA ASSOCIATION of SANITATION AGENCIES 1225 81"Street,Suite 595•Sacramento,CA 95814•TEL:(916)446-0388•www.CASAweb.org Y IPES1ES FLUSHED WIPES CLOGGED SEWER LINES SEWER OVERFLOWS Flushing wet wipes down the Wipes make their way into Once wipes make it to the sewer toilet can clog plumbing private sewer laterals,septic collection system,they can catch systems,leading to expensive systems,and sewer lines on roots that infiltrate pipes, repairs. Many people don't and can cause extensive weave together to form large know that wipes shouldn't go harm and result in overflows rags and attract fats,oils and in the toilet and pose a risk for and property damage. grease.This can result in sewer infrastructure. blockages and sewer spills. MEN ■ ■ ill ENVIRONMENTAL DISRUPTED DAMAGED HARM TREATMENT PLANTS COLLECTION SYSTEMS Even when wipes filter out Oftentimes, masses of wipes Most collection systems rely on of the wastewater stream, manage to make it through the pumps to move wastewater to small microfibers and collection system and end up at treatment facilities.Wipes can microplastics can shed off wastewater treatment plants, clog these pumps,resulting wipes.These fibers can't be which can result in significant in spills,system failures, captured and can make damage to treatment infrastructure increased maintenance their way into the and recurrent disruption of the requirements and damage environment. treatment process. to expensive equipment. Wr CALIFORNIA ASSOCIATION OF SANITATION AGENCIES casaweb.org/wipes Attachment 3 CASA CMUA CALIFORNIA MUNICIPAL UTILITIES T A S S O C I A T I O N ©©W 13 LEAiGUE® ACWA CITIES April 15, 2019 The Honorable Hannah-Beth Jackson, Chair Senate Judiciary Committee State Capitol, Room 2187 Sacramento, CA 95814 RE: SB 332(Hertzberg&Wiener): Oppose Dear Senator Jackson: The coalition of undersigned associations respectfully opposes SB 332 (Hertzberg). As introduced,this measure would mandate wastewater treatment agencies that discharge treated effluent to saline waters, oceans, bays and estuaries to reduce their discharges by 50%of baseline volume by January 1, 2030, and by 95% of baseline volume by January 1, 2040.The bill would also declare that discharge from ocean outfalls is a "waste and unreasonable use" of water and impose penalties of$2,000/acre-foot of water discharged above the reduction requirement. Our coalition strongly supports maximizing water recycling and represents virtually all of the agencies at the forefront of advanced water treatment and reuse in the state. The provisions proposed in SB 332 could significantly disrupt existing efforts to promote recycled water production and use, as well as innovative reuse projects currently being planned and implemented.As a community we are fully supportive of recycled water projects where they are financially viable, where there are opportunities for beneficial use, and where watershed conditions are present to maximize supplies of this water. California has a significant number of wastewater ocean and bay dischargers, and they vary dramatically in terms of treatment capacity, discharge, and the amount of recycling that occurs. Each watershed, region,treatment facility, and outfall is different, and the capability to beneficially reuse wastewater varies widely as well. Reliable and feasible end uses for recycled water are not always available and depend on factors other than simply the discharger's technical ability to supply recycled water. For this reason, a mandate on every ocean and bay discharger in the state is simply unworkable. In many circumstances, regional demand may not exist to reuse 95 percent of an agency's ocean discharge. In addition, recharge and reuse options may be unavailable or infeasible for a variety of reasons, such as geographical or legal constraints in the watershed. Furthermore, distribution can require complex arrangements between water recyclers and water purveyors, brine management may present significant issues in some areas, and public acceptance of beneficial reuse of wastewater remains an obstacle. These challenges exist and require a regional approach to the management of recycled water supplies. The Honorable Hannah-Beth Jackson April 15,2019 Page 2 of 3 There are also a host of other considerations and decisions that agencies must make when prioritizing capital expenditures, including projects critical to public health and environmental protection, not all of which can or should be delayed at the expense of trying to meet a mandate to reuse all treated wastewater. As of today, the regulatory framework necessary for agencies to plan and implement projects to manage the massive volumes of water contemplated in SB 332 does not exist. Existing beneficial reuse options are limited and could not be utilized to manage such a vast quantity of water. Instead, every agency would necessarily need to implement large scale potable reuse projects. The State Water Board is charged with developing regulations for Direct Potable Reuse by 2023. Until that regulatory scheme has been developed it will be nearly impossible for agencies to plan for, let alone implement, projects to meet the mandate deadlines in SB 332. If the regulations are completed on schedule, agencies would then have a seven year window to plan, approve, execute and operate new infrastructure that would dramatically shift their day to day operations.To put this in perspective, some of the most ambitious recycling projects underway in the state currently have 20 to 30 year project schedules, and when fully operational will still not meet the discharge mandate proposed in the bill. Furthermore, no consideration is being given to these ambitious projects in the development of baseline discharge metrics, nor to other innovative project components such as stormwater capture and treatment. California is already aggressively pursuing maximized water recycling as a regulatory priority. The State Water Board recently adopted revisions to its Recycled Water Policy that,for the first time, require wastewater treatment plants and recycled water producers to report the volume of wastewater treated and discharged, specify the level of treatment, and identify the volume of recycled water produced.The policy also requires annual reporting of monthly volume of treated wastewater discharged to the environment, which will be used to estimate the amount of wastewater that may be available to recycle. There are numerous technical realities in the wastewater treatment and management processes that have not been considered in SB 332.The bill lacks consideration of major operational issues surrounding brine management,wet weather influent management, existing regulatory constraints relative to minimum flows, and other real and substantive conflicts with how wastewater agencies function in their communities.These technical issues are vast, far reaching, and vary based on the regional watershed and individual permitting levels. It is important to note that some of California's most ambitious policy goals are not accounted for in SB 332, and we believe the implementation of the proposed mandate would have far reaching impacts that are contrary to those goals. For example, California is a leader on climate change mitigation and adaptation and has taken several steps in recent years to curb emissions and transition to a more sustainable future. SB 332 could adversely impact those efforts by increasing the emissions associated with advanced wastewater treatment and the associated energy demand required to move the high volumes of water over or across a variety of geographical settings. California is simultaneously pursuing policies to make living more affordable for all residents of the state. Unfortunately, SB 332 makes no consideration of the impacts that the massive proposed infrastructure would have on rate increases in the immediate future for a significant portion of the state's population, including some of the most disadvantaged communities in California. The proposed mandate would require rate increases in the order of hundreds of dollars per month per household in the impacted communities.The rate implications would likely have a trickle-down effect of impacting housing affordability as well, as connection fees and ongoing rates would necessarily increase living expenses and the cost of new development in impacted areas. The Honorable Hannah-Beth Jackson April 15,2019 Page 3 of 3 Finally, as California grapples with how to provide safe, affordable, clean drinking water for all,this bill would unnecessarily create additional strain on the limited resources available to fund clean water projects.To the extent that coastal agencies seeking to meet this mandate would be expected to apply for and absorb the limited existing grant and loan opportunities available to them, this would inevitably draw funds away from numerous inland areas (such as the Central Valley) where there are so many urgent drinking water and clean water priorities in need of funding. Our initial estimate is that implementing the mandate in SB 332 is expected to cost local water and wastewater agencies across the state more than $20 billion to comply.That burden would necessarily be borne by ratepayers, and the magnitude of the rate impacts to individual households and businesses in impacted communities would be staggering. As stated above, our organizations are at the forefront of water recycling innovation, and we share the goal of maximizing recycled water to the fullest extent feasible in California. Unfortunately, SB 332 does not provide a workable pathway toward achieving that goal, so we must respectfully oppose the bill. Thank you for your consideration of our concerns. Sincerely, 9Y�A'Abg"_ Jessica Gauger California Association of Sanitation Agencies Danielle Blacet California Municipal Utilities Association Rylan Gervase California Special Districts Association 11 Adam Quinonez Association of California Water Agencies pv_az P4 Derek Dolfie League of California Cities Attachment 4 Alm`k*� Central Contra Costa Sanitary District agink Protecting,public health and the en vironment 5019 Imhoff Place, Martinez, CA 94553-4392 PHONE: (925)228-9500 April 17, 2019 FAX.- (925)335-7744 www.centralsan.org ROGER S.BAILEY General Manager The Honorable Ben Allen, Chair KENTONL.ALM Senate Environmental Quality Counseljorthe District State Capitol, Room 2205 (510)375-4571 KATIE YOUNG Sacramento, California 95814 Secretary of1he District Subject: SB 69 (Wiener): Oppose Dear Senator Allen: The Central Contra Costa Sanitary District (Central San) has taken an Oppose position on SB 69 (Wiener). SB 69 includes a provision that would require the State Water Resources Control Board to amend the California Ocean Plan and the California Enclosed Bays and Estuaries Plan to include water quality objectives and effluent limitations that specifically address ocean acidification and hypoxia. Furthermore, the bill would require the water quality objectives and effluent limitations to include implementation provisions, including, but not limited to, requiring all publicly operated wastewater treatment facilities, which Central San has, that discharge to waters subject to the plans, to adopt, incorporate, or improve denitrification protocols. As proposed, SB 69 would require all wastewater dischargers subject to the California Ocean Plan and the California Enclosed Bays and Estuaries Plan to adopt, incorporate or improve denitrification protocols. The potential impact from discharges of nitrates and remediation is a complicated and nuanced issue for which there is a significant amount of research currently underway and for which many technological advances are being made relative to management options. In the San Francisco Bay Area, Central San is a participant in large-scale studies and management plans for nitrification. These studies are currently being employed in conjunction with California Regional Water Quality Control Boards. California's Regional Water Quality Control Boards currently have the authority to require wastewater agencies to comply with water quality requirements and can impose requirements for planning and implementation of processes to decrease nitrogen loadings in receiving waters. In fact, in the San Francisco Bay Area, the Regional Water Board issued the first nutrients watershed permit in 2014 covering 37 agencies who discharge to San Francisco Bay, including Central San, with the second nutrients watershed permit slated for adoption in May 2019. ®Recycled Paper Subject: SB 69 (Wiener): Oppose April 17, 2019 Page 2 As an active participant in science-based studies, Central San believes it is improper and unnecessary to reopen both the Ocean and Enclosed Bays and Estuaries Plan to a prescribed a statewide blanket requirement on all wastewater agencies to employ denitrification protocols. This approach provides a lack of understanding as to the nuances of regional water issues, which require regional and science-based approaches to address. For the reason stated above, Central San opposes SB 69 (Wiener). Thank you for your consideration of our concerns. J ely, S. Bailey al Manager cc: Senator Scott Wiener Senate Environment Quality Committee Members