Permitting Pollution

by Carolyn Chase


hen having to select between ignorance, stupidity or corruption, I always try and opt for ignorance first. Give people the benefit of the doubt, I figure. But repeated exposure to political decision-making can test the mettle of the most compassionate observer.

In preparation for jet ski races seeking a special event permit in order to be held in Mission Bay this October, the City has issued a Mitigated Negative Declaration (MND) as required by the California Environmental Quality Act, but declined to hold any other hearings.

In the past, much smaller events have been brought before the Mission Bay Park Committee for discussion and approval, substantially prior to this point. Examples are the addition of drag boat racing to the Thunder Boat Races in 1997/98, the first Rock & Roll Marathon in the summer of 1998, and the annual reconsideration of the Hospitality Point summer concerts.

There are other, long established events which now do not return for annual approval, such as the Crew Classic and the Thunder Boats. All such events are expected to pay park use fees and a percentage of revenues into specified Mission Bay and/or City accounts, unless a waiver has been approved by Council. Again, this has usually required public hearings from the appropriate park subcommittee, up through the Park & Recreation Board, Council committee and then Council - none of which has taken place for this jet ski event.

When the question was raised at the June 1, 1999 Mission Bay Committee meeting about why this had not been brought before the Committee months before, the Chair responded that he had not considered it to be an event with sufficient impact on Fiesta Island and Mission Bay activities. However, an 8-day racing event and a total of 21 days of setup, racing, exhibits and takedown will have substantial impacts.

The two-stroke engines that power most jet skis run on a mixture of oil and gasoline. They discharge as much as one-third of this mixture - unburned - into the water. These machines burn from 8-12 gallons of gas per hour of operation. This event proposes to field as many as 750 jet skis, pumping thousands of gallons of raw fuel into the water. The fuel that is burned turns into air pollution.

The California Air Resources Board has reported that a two-hour ride on a 100-horsepower jet ski emits the same amount of pollution as driving 139,000 miles in a 1998 passenger car! The City's recently amended MND states "... the proposed 2,576 hours of jet ski operations would equate to a total of 36,800,000 vehicle miles over eight days (54% of a single day's existing miles [this is for the whole County by the way]). The percent increase during the eight days of racing seems substantial in relation to the daily baseline condition but, due to the temporary nature of the event, the increase is not significant over a longer term." Duh. Any effect is insignificant if averaged over a long enough term. That sentence actually makes me want to scream. Can anyone offer any outrage advice?

In addition, with respect to water pollution, it states, "The project would discharge 9,274 gallons of fuel into the bay in October, but this contribution would represent a 60% increase over September's current discharge rate. In other words, the discharge due to the event would be comparable to adding an additional two weeks of existing summer time discharges and this addition would occur after what is expected to be the peak summertime usage period." Their day-by-day estimates of the increases in discharges range from an increase of 67 to 455% per day. The City's conclusion? "Water quality impacts are not significant and no mitigation is required."

Hydrocarbons in gas and oil released from two-stroke motors float on the surface of the water and settle within the shallow ecosystems. These areas are home to many organisms at the base of the food chain: fish eggs, algae, shellfish, and zooplankton. Scientists have determined that hydrocarbon pollution can bioaccumulate within the complex food web and pose a threat to the marine environment.

According to Michigan State's Dr. John Giesy, one of the world's leading experts on the toxicological effects of marine hydrocarbon
pollution, the two-stroke emissions released into the water are up to 50,000 times more toxic under field conditions in the presence of the ultraviolet (UV) light in sunlight. This is due to polycyclic aromatic hydrocarbons (PAHs), substances contained in petrochemicals that form highly toxic and persistent compounds known to be: 1. ubiquitous contaminants that bioconcentrate; 2. carcinogenic to mammals; and 3. acutely photo-toxic to aquatic organisms within minutes or hours.

Through controlled experiments, Dr. Giesy found that it takes .05 ppb (parts per billion) of PAHs in water to cause a ten percent decrease in zooplankton; as little as five ppb (parts per billion) killed all zooplankton in a thirty minute test period. Sampling has found PAH levels substantially in excess of five ppb during recreational boating activity. PAH's are considered so dangerous that the New York State Department of Environmental Conservation now regulates PAHs on the same toxicity level as known cancer-causing PCBs (polychlorinated biphenols). Research demonstrates that chromosomal damage, reduced growth and high mortality rates of fish occur at extremely low levels of hydrocarbon pollution. Scientists believe that such pollution may bioaccumulate, degrading the surrounding environment.

The San Diego Basin Plan, which establishes narrative water quality standards for this area, states that "water shall not contain oils, greases, waxes or other materials in concentrations which results in a visible film or coating on the surface of the water," and "All water shall be maintained free of toxic substances in concentrations that are toxic to or that produce detrimental physiological responses in human, plant, animal or aquatic life."

Mission Bay is already listed as an impaired water body under the Clean Water Act. This means we already don't meet the state's water quality standards after full implementation of the state's existing permits. Mission Bay is already too polluted to support it's designated and existing uses. And Clean Water Act regulations prohibit new water discharges that will cause or contribute to the violation of water quality standards.

What is our city's response? The mitigation suggested for the water pollution impacts of this event in the MND is to "require locating drip pans under all watercraft in the pit areas."

Two-stroke engines are so bad that jet ski manufacturers recently settled a lawsuit brought by several California environmental groups. The settlement includes phasing out sales of two-stroke marine engines in the State of California.

I want to know why this industry doesn't step up and clean up its act. They have the tools, the technology and the money. What they evidently don't have is any sense of shame or responsibility for the byproducts of their fun and good fortunes. One jet skier was quoted saying, "It's too bad they're against it, it's so fun!" Well, no one is against the fun, and everyone should be against the pollution and the cheap practices that keep dirty technology in use. If we have to keep giving up our public parks for commercial enterprises, at the very least they should be clean ones.

The City now claims that it was just an oversight that the pollution outputs were overlooked in the original MND. They are issuing the permit and are evidently getting ready to defend the position that pouring thousands of gallons of pollutants into the air and water will be an insignificant impact. Dilution is their solution to pollution.

They will also not be holding any public hearings. For public input we must turn to the California Coastal Commission, who again will be facing that sensitive choice about submissions from the City of San Diego: ignorance, stupidity, or corruption. Some have suggested it's just plain greed. At this point, I have to wonder if they don't deserve some votes in all categories.