Proposed State Rainwater Rules Just Drops in Regulation Bucket

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Two views

An article headlined “Rainwater Rules to Soak L.A. Businesses?” in the Aug. 22 issue dealt with state proposals that may require some businesses to capture and clean rainwater before it runs off their property. This would particularly affect the many industrial properties, truck yards and the like in Los Angeles County. Here are two of the responses generated by that article.

The present and proposed regulations regarding water runoff are a mixture of good requirements, poor requirements and ridiculous requirements. It’s important for advocates and regulators to decide if they want results – less pollution in the ocean – or just want to push businesses around.

Yes, stopping pollution at the source is good. It’s far easier to stop pollution than to remediate it. It’s far cheaper to stop pollution versus trying to remove it from a large volume of water, regardless of who is paying the bill.

In regards to stopping pollution at the source, it’s ridiculous that nothing is done about all the used car oil that ends up in the storm drain. We have a state redemption program on recyclable soda cans and bottles. It would make a lot of sense to have an incentive fee for the return of used motor oil. There are hundreds of thousands of people in Los Angeles who dump used motor oil in the storm drains because there is no incentive to do otherwise and because it’s impossible to police the activity. So forget fines for individuals – put an incentive for good behavior in place. It’s not going to be perfect but doing nothing is worse.

Testing runoff water for pollution is good. Requiring every business property owner to do it themselves is silly, a recipe for failure. Many good business owners do not have the skills to do it correctly. You can require every owner to have runoff testing done by a testing organization. You can and should have regulatory oversight of the test firms to ensure quality results, correct methodology and cost-effectiveness.

It’s ridiculous that the business property owner is responsible for water than runs onto his property and then off his property. If the pollution is occurring uphill, then he has no control. Holding a landowner responsible for polluted water he cannot control may or may not be legal, but it certainly is not going to be very effective.

What about runoff from residential property? Isn’t pollution in the ocean still pollution if it comes from the property of a voter rather than a business? What would you guess is the ratio of residential to business property? If residential acreage is the majority, then how is ignoring it going to be helpful in solving this issue?

Nonbusiness properties

What about nonbusiness properties? Is there really zero pollution in the runoff from the parking lots at the Los Angeles Memorial Coliseum, Los Angeles City Hall and Los Angeles International Airport? How about streets and freeways? If we are after results, shouldn’t these potential pollution sources also be tested and treated? If preventing runoff pollution is important, then the runoff from all types of property should be considered!

Trying to treat the runoff from each business property, on each property, only when it is raining is ridiculous. It would be far better to have bulk or regional treatment of water from storm drains. The economics of treating water are well established. We don’t build separate sewage treatment plants on each property; we gather the effluent and treat it in large plants. This is because of a principle of economics called “economy of scale.”

Also, treating runoff water only when it is raining is almost impossible. Does anyone really imagine that every property owner will be able to keep the equipment instantly ready to work and that it will operate correctly when it rains? It does not rain much in Los Angeles, but when it does, it rains hard and fast. Most of the time the equipment will sit around doing nothing (a recipe for breakdowns) and then it will be overwhelmed by the rate of flow. What about operating personnel? Are they going to be available any time – I repeat, any time – it rains?

A better idea would be to use partially treated water (toilet to tap for example) to flush runoff from property and storm drains into processing plants on a regular basis. Engineers already design plants for that and the treatment would be far more effective than treating only rain water during storms. Since that kind of water flush would be planned, the equipment can be operated by trained personnel without excessive overtime.

So a little thinking big. Treat waste water and use it to flush storm drains. Build that distribution infrastructure. Divert the storm drain water and treat it in regional plants. Build those plants. Mitigate all sources of pollution with measures that work – not just measures that poll well. Create and implement those measures.

I’ll close with my opening: Is this about results or is this about power?

Mike Paik is an engineer in Montebello.

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