In a message dated 4/7/2005 4:24:24 P.M. Pacific Standard Time, [email protected] writes:

Dear John--

The health department strongly believes in open and transparent information
sharing with the public as a means to promote and protect public health.

I have read Ms. Weintraub's reponse to you carefully.  She simply informs
you that we do act to prevent health threats where necessary.  An example
is when we post a warning on a beach.   While you do have the right to say
anything you wish, it was neither helpful nor fair for you to characterize
her message in the way you did.

Rajiv
____________________________________

Rajiv Bhatia, MD, MPH.
Director, Occupational & Environmental Health,
San Francisco Department of Public Health

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To w;hich we responded:
 
Rajiv:
 
It may or may not be helpful, but it certainly is accurate to "characterize (June's) message in the way that (I) did".
 
June said: "As you know, Lake Merced is designated an emergency water supply, and as such, swimming and other full body contact uses are prohibited.  Because there are no bacteria standards for recreational boating and fishing uses of this body of water, there is not a compliance issue in this case."
 
It is a fundamental rule of syllogistic logic that If A then B, If B then C, A is true, then C is true.  June said, If emergency supply of drinking water then no swimming, if no swimming then no standards, if no standards then no compliance issue.
 
June is incorrect that there are no standards for infrequent contact recreational use in fresh water bodies.  I have sent June the EPA standards for that class of uses.  I believe that it is adopted PUC policy to meet or exceed all EPA standards, as well as the state issued regulations.  I'm disappointed that I am the one who needs to find this stuff on the web.  I'm also disappointed that I have had to turn to the San Diego Department of Environmental Health to find resources describing fresh water specifications and minimum standards for water quality monitors.
 
June also said: "If there is evidence that the coliform levels do present a health threat to these boating and fishing users, we can consider taking action to prohibit those uses."

Coliform levels periodically present a health issue in recreational waters all over the state.  Where that is the case monitoring programs are established that provide for adequate protection of the recreational public.  Notices are posted, and beaches are cleared.  We don't, however, prohibit swimming at places like Mission Bay in San Diego just because a quarantine is periodically required.  June's suggestion is completely insensitive both to standard monitoring approaches and to the great importance of protecting Lake Merced as a recreational resource.  For many inner city youth this is the closest they are ever going to get to outdoor boating and fishing opportunities.  To willingly discard those opportunities rather than develop an appropriate monitor is in my view intolerable.
 
What June did not say is, Yes, let's get together and work out a practical and effective monitoring program for Lake Merced.  Instead, she did say, "We do not believe that instituting a monitoring program in the absence of a regulatory standard for that body of water will improve protection of the public health."
 
It seems to me that before I raised the alarm we had no health threats at Lake Merced.  Certainly the PUC didn't think so, as they waited more than three months to release a report that E-coli levels in South Lake had reached 985 MPN.  Their response was to suggest a monitoring program that would be conducted every two months, with reports delayed a further 30 days, no matter what condition had been observed at the lake, and with no provision for public notice other than sending me a copy of the report.  They made this proposal after measuring the high levels of E-coli and before releasing the report, a sequence that does little to engender public confidence.  However, it seems clear to me that if I'd just shut up and go away, quit rattling the City's chain, we wouldn't have any health problems, at least none that we recognized.
 
Well, there is a regulatory standard, and there is the need for a monitoring program, and fortunately the PUC agrees with both of those conclusions without the support of the Public Health Department.  I think that's also a shame.
 
John

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John Plummer
Friends of Lake Merced
[email protected]
www.lakemerced.org