194 



Suifrider 

 Foundation 



Honorsible Chairman Ortiz 



Subconiaitte , on Oceatiogr aphy , Gulf of Mexico, 



Outer Continental Shelf 



Washington D.C. 20515-6230 



.■'•■, July 8, 1993 



. Dear Chairraan Ortiz-, 



My name ia Dr. Scott A. JenXins. I have been a 

 researcher in Coastal Processes at, the Scripps Institution 

 of Oceanography since 1980. I have also ser-zed as the 

 Environaental Director of the Surfrider Foundation since 

 1990. 1 have conceived and implemented the first all 

 voluntf^er surf zone water quality monitoring program called 

 "The Blue Water Task Porce". 



Based upon this experience and background ^ I report to 

 you that there i» no existing water quality data which 

 implicates the disttharge of primary treated sewage with 

 beach closures when the effluent i« discharged through a 

 properly functioning ocean outfall, instead, more than 

 2,000 beach closures anually are attributable to untreated 

 urban runoff and raw sewage from leaking sewer 

 infrastructure. Most of this kind of non-point source 

 pollution is discharged directly on to the beach through 

 storm drains, who's seemingly benign flow attract yo\ing 

 children. Furthermore storm drain discharges are diluted" 

 relatively slowly in the gurlzone due to the shallow Water 

 depth and Shoreward directed wave energy^ which keeps this 

 pollution pinned against the shoreline. 



In its present form the clean Water Act (CWA) is 

 ineffective in controlling surf zone pollution from urban 

 runoff and, sewer infrastructure leaks. In fact, by forcing , 

 cities like San Diego to divert billions Cf dollars toward 

 secondary treatment levels, the CWA delays effective 

 solutions to the more significant threats to near shore 

 water quality, namely non-point source pollution. In my 

 view the more urgent need is to repair and upgrade the bftsic 

 plumbing of the sewer infrastructure so that all the sewage 

 makes it to the treatment facility. In addition the. 

 capacity of the primary treatment level must be- increased 4- 

 5 times so that the untreated storm drain runoff can also 

 receive at least -primary level treatment and be subsequently 

 discharged offshore through ocean outfalls where the 

 dilution rates are high. 



