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	<title>Comments for GrokSurf&#039;s San Diego</title>
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	<link>http://groksurf.com</link>
	<description>Local observations on water, environment, technology, law &#38; politics</description>
	<lastBuildDate>Wed, 30 May 2012 00:28:16 +0000</lastBuildDate>
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		<title>Comment on Purified recycled water&#8230;it&#8217;s perfectly clear by Burton Freeman</title>
		<link>http://groksurf.com/2012/05/29/purified-recycled-water-its-perfectly-clear/#comment-4856</link>
		<dc:creator><![CDATA[Burton Freeman]]></dc:creator>
		<pubDate>Wed, 30 May 2012 00:28:16 +0000</pubDate>
		<guid isPermaLink="false">http://groksurf.com/?p=19432#comment-4856</guid>
		<description><![CDATA[Yes, a well-produced video on some of the issues re IPR.  The arguments for potable reuse of water point to several different local sources of San Diego County (and city) water.  The goals are safety, reliability and cost-effectiveness.  No doubt, these also imply diversification of supply, as well as reduction in demand.  It is remarkable that conservation, aquifers, purple pipes and seawater desalination don&#039;t get some face-time; they are all part of a menu that is on the competitive water market!

As for IPR, questions remain regarding sequestration in a surface water body, amount of available advance water supply and cost.  Le&#039;s restrain our enthusiasm for IPR until all of the facts are available.]]></description>
		<content:encoded><![CDATA[<p>Yes, a well-produced video on some of the issues re IPR.  The arguments for potable reuse of water point to several different local sources of San Diego County (and city) water.  The goals are safety, reliability and cost-effectiveness.  No doubt, these also imply diversification of supply, as well as reduction in demand.  It is remarkable that conservation, aquifers, purple pipes and seawater desalination don&#8217;t get some face-time; they are all part of a menu that is on the competitive water market!</p>
<p>As for IPR, questions remain regarding sequestration in a surface water body, amount of available advance water supply and cost.  Le&#8217;s restrain our enthusiasm for IPR until all of the facts are available.</p>
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		<title>Comment on Purified recycled water&#8230;it&#8217;s perfectly clear by merle Moshiri</title>
		<link>http://groksurf.com/2012/05/29/purified-recycled-water-its-perfectly-clear/#comment-4855</link>
		<dc:creator><![CDATA[merle Moshiri]]></dc:creator>
		<pubDate>Tue, 29 May 2012 22:42:01 +0000</pubDate>
		<guid isPermaLink="false">http://groksurf.com/?p=19432#comment-4855</guid>
		<description><![CDATA[Items like this must send a shudder down the spine of Poseidon.  Uh oh! a viable alternative to desal? cheaper, reliable, provides more jobs?  Well, maybe some of the fat cats might not make as much money but.....we all have to sacrifice.

Merle Moshiri, President
Residents for Responsible Desalination
Huntington Beach, CA]]></description>
		<content:encoded><![CDATA[<p>Items like this must send a shudder down the spine of Poseidon.  Uh oh! a viable alternative to desal? cheaper, reliable, provides more jobs?  Well, maybe some of the fat cats might not make as much money but&#8230;..we all have to sacrifice.</p>
<p>Merle Moshiri, President<br />
Residents for Responsible Desalination<br />
Huntington Beach, CA</p>
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		<title>Comment on Advances in water recycling approved by San Diego City Council NR&amp;C Committee by Craig</title>
		<link>http://groksurf.com/2012/05/24/advances-in-water-recycling-approved-by-san-diego-city-council-nrc-committee/#comment-4854</link>
		<dc:creator><![CDATA[Craig]]></dc:creator>
		<pubDate>Tue, 29 May 2012 17:22:40 +0000</pubDate>
		<guid isPermaLink="false">http://groksurf.com/?p=19325#comment-4854</guid>
		<description><![CDATA[If you haven&#039;t already, you may want to check out AB 2398 (Hueso), introduced Feb. 24, 2012: http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_2351-2400/ab_2398_bill_20120224_introduced.html. Status is here: http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_2351-2400/ab_2398_bill_20120525_status.html.]]></description>
		<content:encoded><![CDATA[<p>If you haven&#8217;t already, you may want to check out AB 2398 (Hueso), introduced Feb. 24, 2012: <a href="http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_2351-2400/ab_2398_bill_20120224_introduced.html" rel="nofollow">http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_2351-2400/ab_2398_bill_20120224_introduced.html</a>. Status is here: <a href="http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_2351-2400/ab_2398_bill_20120525_status.html" rel="nofollow">http://www.leginfo.ca.gov/pub/11-12/bill/asm/ab_2351-2400/ab_2398_bill_20120525_status.html</a>.</p>
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		<title>Comment on Advances in water recycling approved by San Diego City Council NR&amp;C Committee by George J. Janczyn</title>
		<link>http://groksurf.com/2012/05/24/advances-in-water-recycling-approved-by-san-diego-city-council-nrc-committee/#comment-4846</link>
		<dc:creator><![CDATA[George J. Janczyn]]></dc:creator>
		<pubDate>Sat, 26 May 2012 00:14:19 +0000</pubDate>
		<guid isPermaLink="false">http://groksurf.com/?p=19325#comment-4846</guid>
		<description><![CDATA[Thanks for clearing that up Brent.]]></description>
		<content:encoded><![CDATA[<p>Thanks for clearing that up Brent.</p>
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		<title>Comment on Advances in water recycling approved by San Diego City Council NR&amp;C Committee by Brent</title>
		<link>http://groksurf.com/2012/05/24/advances-in-water-recycling-approved-by-san-diego-city-council-nrc-committee/#comment-4845</link>
		<dc:creator><![CDATA[Brent]]></dc:creator>
		<pubDate>Sat, 26 May 2012 00:02:28 +0000</pubDate>
		<guid isPermaLink="false">http://groksurf.com/?p=19325#comment-4845</guid>
		<description><![CDATA[Section 301 (h) of the Clean Water Act (the provision that allows modified discharge permits (waivers) to be granted) is absolutely silent on water re-use.  The primary conditions of a waiver are pre-treatment (which the City does), treatment to certain standards (Pt. Loma operates at advanced primary which exceeds the legal requirements of treatment for a waiver), no new or substantially increased discharges (the City&#039;s permitted discharge quantity is well higher than the actuals.  Water conservation has been helpful, but even before the big push to conserve, discharge volume was well below the permit level), and monitoring of impacts on the environment from the discharge (San Diego has one of the most comprehensive and robust monitoring programs in the nation).  Nowhere is there a legal connection to re-use.

The only requirement from EPA for the City to re-use water is in Section 301 (j).  That required the City to achieve a system capacity of 45,000,000 gallons of reclaimed waste water per day by January 1, 2010.  A provision we met (North City and South Bay Reclamation Plants).

There is some question as to the State’s ability (thru the CA Coastal Commission) to require re-use as a condition of determining federal consistency.  However, if you followed the last waiver process closely, you probably know that the late CCC Exec Director provided guidance to his board, on several occasions, that if the Board took that action, they would likely be subjecting themselves to litigation, for which they did not have a strong foundation.  Ultimately, the CCC approved the consistency determination with the only condition being that the City report back on the final Recylced Water Study.  Despite the CCC’s best efforts, the City was successful in ensuring that that condition did not have any implementation requirements.  The City agreed to that condition and did not contest it, though it had a legal right to do so.

So, all this is to say that it’s not really accurate to state that implementation of any sort of water re-use is the only way the City would be assured it will qualify for more waivers.  It may be the only way certain organizations don’t submit letters of opposition to a waiver application, but fortunately they don’t’ have any legal authority over issuing permits.  To be more accurate, the only way Pt. Loma will qualify is if the City continues to operate Pt. Loma within the conditions of the current NPDES permit and in full compliance with the Clean Water Act.  If it fails to do that, future waivers are certainly at risk.]]></description>
		<content:encoded><![CDATA[<p>Section 301 (h) of the Clean Water Act (the provision that allows modified discharge permits (waivers) to be granted) is absolutely silent on water re-use.  The primary conditions of a waiver are pre-treatment (which the City does), treatment to certain standards (Pt. Loma operates at advanced primary which exceeds the legal requirements of treatment for a waiver), no new or substantially increased discharges (the City&#8217;s permitted discharge quantity is well higher than the actuals.  Water conservation has been helpful, but even before the big push to conserve, discharge volume was well below the permit level), and monitoring of impacts on the environment from the discharge (San Diego has one of the most comprehensive and robust monitoring programs in the nation).  Nowhere is there a legal connection to re-use.</p>
<p>The only requirement from EPA for the City to re-use water is in Section 301 (j).  That required the City to achieve a system capacity of 45,000,000 gallons of reclaimed waste water per day by January 1, 2010.  A provision we met (North City and South Bay Reclamation Plants).</p>
<p>There is some question as to the State’s ability (thru the CA Coastal Commission) to require re-use as a condition of determining federal consistency.  However, if you followed the last waiver process closely, you probably know that the late CCC Exec Director provided guidance to his board, on several occasions, that if the Board took that action, they would likely be subjecting themselves to litigation, for which they did not have a strong foundation.  Ultimately, the CCC approved the consistency determination with the only condition being that the City report back on the final Recylced Water Study.  Despite the CCC’s best efforts, the City was successful in ensuring that that condition did not have any implementation requirements.  The City agreed to that condition and did not contest it, though it had a legal right to do so.</p>
<p>So, all this is to say that it’s not really accurate to state that implementation of any sort of water re-use is the only way the City would be assured it will qualify for more waivers.  It may be the only way certain organizations don’t submit letters of opposition to a waiver application, but fortunately they don’t’ have any legal authority over issuing permits.  To be more accurate, the only way Pt. Loma will qualify is if the City continues to operate Pt. Loma within the conditions of the current NPDES permit and in full compliance with the Clean Water Act.  If it fails to do that, future waivers are certainly at risk.</p>
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		<title>Comment on QSA-related federal lawsuit case denied by jrfleck</title>
		<link>http://groksurf.com/2012/04/10/qsa-related-federal-lawsuit-case-denied/#comment-4679</link>
		<dc:creator><![CDATA[jrfleck]]></dc:creator>
		<pubDate>Tue, 10 Apr 2012 18:20:31 +0000</pubDate>
		<guid isPermaLink="false">http://groksurf.com/?p=19068#comment-4679</guid>
		<description><![CDATA[Thanks so much for posting this, especially for sharing the ruling.]]></description>
		<content:encoded><![CDATA[<p>Thanks so much for posting this, especially for sharing the ruling.</p>
]]></content:encoded>
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		<title>Comment on Chris Austin does Imperial Valley water with style by mjlehner</title>
		<link>http://groksurf.com/2011/08/18/chris-austin-does-imperial-valley-water-with-style/#comment-4599</link>
		<dc:creator><![CDATA[mjlehner]]></dc:creator>
		<pubDate>Fri, 16 Mar 2012 17:16:06 +0000</pubDate>
		<guid isPermaLink="false">http://groksurf.com/?p=17066#comment-4599</guid>
		<description><![CDATA[Can&#039;t wait! (But I will)]]></description>
		<content:encoded><![CDATA[<p>Can&#8217;t wait! (But I will)</p>
]]></content:encoded>
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		<title>Comment on Chris Austin does Imperial Valley water with style by Chris Austin</title>
		<link>http://groksurf.com/2011/08/18/chris-austin-does-imperial-valley-water-with-style/#comment-4598</link>
		<dc:creator><![CDATA[Chris Austin]]></dc:creator>
		<pubDate>Fri, 16 Mar 2012 17:04:35 +0000</pubDate>
		<guid isPermaLink="false">http://groksurf.com/?p=17066#comment-4598</guid>
		<description><![CDATA[Actually, I am working on exactly that - following the San Andreas Fault system and doing a slide show that will cover it from end to end.  It just going to take me a few years (unfortunately) to travel the length of the fault.

Thanks so much for the complement!]]></description>
		<content:encoded><![CDATA[<p>Actually, I am working on exactly that &#8211; following the San Andreas Fault system and doing a slide show that will cover it from end to end.  It just going to take me a few years (unfortunately) to travel the length of the fault.</p>
<p>Thanks so much for the complement!</p>
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		<title>Comment on Chris Austin does Imperial Valley water with style by mjlehner</title>
		<link>http://groksurf.com/2011/08/18/chris-austin-does-imperial-valley-water-with-style/#comment-4597</link>
		<dc:creator><![CDATA[mjlehner]]></dc:creator>
		<pubDate>Fri, 16 Mar 2012 16:27:08 +0000</pubDate>
		<guid isPermaLink="false">http://groksurf.com/?p=17066#comment-4597</guid>
		<description><![CDATA[PS: I have gone through all of Chris Austin&#039;s work that I can find and it is all splendid. The one above about Imperial Valley and the diversion of the Colorado River&#039;s water is just great. The pictures make it real for me.]]></description>
		<content:encoded><![CDATA[<p>PS: I have gone through all of Chris Austin&#8217;s work that I can find and it is all splendid. The one above about Imperial Valley and the diversion of the Colorado River&#8217;s water is just great. The pictures make it real for me.</p>
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		<title>Comment on Chris Austin does Imperial Valley water with style by mjlehner</title>
		<link>http://groksurf.com/2011/08/18/chris-austin-does-imperial-valley-water-with-style/#comment-4596</link>
		<dc:creator><![CDATA[mjlehner]]></dc:creator>
		<pubDate>Fri, 16 Mar 2012 16:24:14 +0000</pubDate>
		<guid isPermaLink="false">http://groksurf.com/?p=17066#comment-4596</guid>
		<description><![CDATA[http://www.sci.sdsu.edu/salton/San%20AndreasFaultSyst.html This is a link that describes the San Andreas fault from north of San Francisco all the way down to Mexico. If Chris Austin could take this piece, add her photo-journalistic skills to it and put together one of her pictorial documentaries, this information would be transformed. I read through the information in the link and while it is fabulous in it&#039;s content, I just cannot visualize the areas described. This would be so much better if Maven could apply her art to it!]]></description>
		<content:encoded><![CDATA[<p><a href="http://www.sci.sdsu.edu/salton/San%20AndreasFaultSyst.html" rel="nofollow">http://www.sci.sdsu.edu/salton/San%20AndreasFaultSyst.html</a> This is a link that describes the San Andreas fault from north of San Francisco all the way down to Mexico. If Chris Austin could take this piece, add her photo-journalistic skills to it and put together one of her pictorial documentaries, this information would be transformed. I read through the information in the link and while it is fabulous in it&#8217;s content, I just cannot visualize the areas described. This would be so much better if Maven could apply her art to it!</p>
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