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The community has a fundamental legal right to clean water for drinking,
cooking and bathing. The integrity of these uses have priority over any other
uses and cannot be challenged by special interests or political expediencies.
These rights are guaranteed by the California State Constitution’s Health
and Welfare clause, the Clean Water Act, which requires health based standards;
the Clean Water Bond Act, which is the mechanism provided to clean up
contaminated water to the level of health based standards established by the
State Office of Health Hazard Assessment; and the California Environmental
Quality Act that screens development according to these standards. The proposed
EIR, issued by the DWP for reclaimed water use, does not even acknowledge these
standards. The standard proposed by the DWP, the Maximum Contaminant Level, is
based on ten year old technology and cost that was intended to apply to a clean
water source... not wastewater.
The "toilet to tap" reclaimed water project, intended for potable
water use, should be considered only as a last resort, according to the National
Research Council. Large-scale experiments on people, such as has been taking
place in the Montebello area for many years, indicates an unprecedented level of
bureaucratic hubris. The effort to widen the experiment to include San Fernando
Valley and environs should not be tolerated.
Nobody really knows what agents of infection or hazardous chemicals will be
injected into the aquifer. The EIR does not deny this. It fails to consider, for
example, that the chlorine treatment meant to disinfect the waste water will
convert chromium 3, which is harmless, into Chromium 6, one of the most
dangerous chemicals and will result in a buildup of this deadly toxin in the
underground water supply – the direct result of injecting treated wastewater
into the aquifer. Chromium 6 has been judged a carcinogen by the Office of
Health Hazard Assessment because it is bio-accumulative. That means that it does
not leave the body, but accumulates in organs like the liver, kidneys and
spleen, over long periods of time, causing cancers and unknown effects on the
outcomes of pregnancies. There is no safe level. The danger depends on how much
water people drink, how much they cook, and how much they bathe.
What can happen if the DWP is wrong? Can the damage be repaired? Are they
setting us up for a public health catastrophe? What are the odds? The EIR lacks
an environmental risk assessment. How does the DWP know that there is no risk?
Experimenting on human populations is still contrary to the ways in which we
do things in this society.
—Bill Firschein, Architect & builder, specializing in preservation and
environmental technology
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