DESALINATION WITH A GRAIN OF SALT – A California Perspective.

Pacific Institute for Studies in Development, Environment, and Security, California
Written by: Heather Cooley, Peter H. Gleick, and Gary Wolff .

See whole report here http://www.pacinst.org/reports/desalination/desalination_report.pdf
or refer to links in left hand column.

JUNE 2006

Brine Composition and Discharge

Adequate and safe disposal of the concentrated brine produced by the plant presents a significant environmental challenge. Brine salinity depends on the salinity of the feedwater, the desalination method, and the recovery rate of the plant. Typical brines contain twice as much salt as the feedwater and have a higher density. In addition to high salt levels, brine from seawater desalination facilities can contain concentrations of constituents typically found in seawater, such as manganese, lead, and iodine, as well as chemicals introduced via urban and agricultural runoff,

Subsurface intake wells use sand as a natural filter and can reduce or eliminate impingement and entrainment of marine organisms and reduce chemical use during pre-treatment. such as nitrates (Talavera and Ruiz 2001), and impinged and entrained marine organisms killed during the desalination process, as noted above.

Composition

Chemicals used throughout the desalination process may also be discharged with the brine. The majority of these chemicals are applied during pre-treatment to prevent membrane fouling (Amalfitano and Lam 2005). For example, chlorine and other biocides are applied continuously to prevent organisms from growing on the plant’s interior, and sodium bisulfite is then often added to eliminate the chlorine, which can damage membranes. Anti-scalants, such as polyacrylic or sulfuric acid, are also added to prevent salt deposits from forming on piping. Coagulants, such as ferric chloride and polymers, are added to the feedwater to bind particles together.

The feedwater, with all of the added chemicals, then passé through a filter, which collects the particulate matter. The RO membranes reject the chemicals used during the desalination process into the brine. The particulate matter on the filter is also discharged with the brine or collected and sent to a landfill.

In addition to using chemicals for pre- treatment, chemicals are required to clean and store the RO membranes. Industrial soaps and dilute alkaline and acid aqueous solutions are commonly used to clean the membranes every three to six months. The membranes are then rinsed with product water. The first rinse, which contains a majority of the cleaning solution, is typically neutralized and disposed of in local treatment systems.

Subsequent rinses, however, are often discharged into the brine. Frequent cleaning and replacement of the membranes due to excess membrane fouling may lead to discharges in violation of sanitary system discharge permits. This problem has occurred in Tampa Bay.

ASSESSING THE ADVANTAGES AND DISADVANTAGES OF DESALINATION

Brine also contains heavy metals introduced during the desalination process. Corrosion of the desalination equipment leaches a number of heavy metals, including copper, lead, and iron, into the waste stream. In an early study of a desalination plant in Florida, Chesher (1975) found elevated copper and nickel levels in the water column and in sediments near the brine discharge point. Copper levels were particularly high during unstable operating periods and immediately following maintenance, although engineering changes made at the plant permanently reduced copper levels.

Perhaps the best way to reduce the effects of brine disposal is to reduce the volume of brine that must be discharged and minimize the adverse chemicals found in the brines. Both man-made filters and natural filtration processes can reduce the amount of chemicals applied during the pre-treatment process. Ultrafiltration, for example, can replace coagulants, effectively removing silt and organic matter from feedwater (Dudek and Associates 2005). Ultrafiltration also removes some of the guesswork involved in balancing the pre-treatment chemicals, as pre-treatment “must be continuously optimized to deal with influent characteristics” (Amalfintano and Lam 2005). These filters, however, are backwashed periodically to remove sludge build up and cleaned with the same solution used on RO membranes. Backwash can be disposed of with the waste brine or dewatered and disposed of on land. Additionally, subsurface intake wells, which use sand as a natural filter, reduce chemical usage during pre-treatment by reducing the biological organisms that cause bio fouling.

Discharge

A number of brine disposal options are available. For desalination plants located on the coast, disposal methods include discharge to evaporation ponds, the ocean, confined aquifers, or saline rivers that flow into an estuary. Options for inland disposal of brines and concentrates include deep-well injection, pond evaporation, solar energy ponds, shallow aquifer storage for future use, and disposal to a saline sink via pipeline or injection to a saline aquifer (NAS 2004).

Each disposal method, however, has a unique set of advantages and disadvantages.

Large land requirements make evaporation ponds uneconomical for many developed or urban areas. Sites along the California coast, for example, tend to have high land values, and coastal development for industrial processes is discouraged. Injection of brine into confined groundwater aquifers is technically feasible, but it is both expensive and hard to ensure that other local groundwater resources remain uncontaminated.

Unless comprehensive and competent groundwater surveys are done, there is a risk of unconfined brine plumes appearing in freshwater wells. Direct discharges into estuaries and the ocean disrupt natural salinity balances and cause environmental damage of sensitive marshes or fisheries. All of these methods add to the cost of the process, and some of them are not yet technically or commercially available.

As noted by the 2003 U.S. Desalination Roadmap, “finding environmentally-sensitive disposal options for this concentrate that do not jeopardize the sustainability of water sources is difficult, and, thus, next-generation desalination plants will have to be designed to minimize the production of these concentrates, or find useful applications for them” (USBR and SNL 2003).

Ocean discharge is the most common and least expensive disposal method for coastal desalination plants (Del Bene et al. 1994), although this approach can have significant impacts on the marine environment.

Brine discharged into the ocean can be pure, mixed with wastewater effluent, or combined with cooling water from a co-located power plant.35

Ocean discharge assumes that dilution of brine with much larger volumes of ocean water will reduce toxicity and ecological impacts. The notion that diluting brine with cooling water reduces the toxicity of the brine is based on the old adage, “Dilution is the solution to pollution.” While this may be true for some brine components, such as salt, it does not apply to others. The toxicity of persistent toxic elements, including some subject to bioaccumulation, such as heavy metals, is not effectively minimized by dilution. In addition, little is known about the synergistic effects of mixing brine with either wastewater effluent or cooling water from power plants.

Because brine is typically twice as saline as the feedwater, it has a higher density than the receiving water and exhibits a distinct physical behavior.

As a general rule, brine follows a downward trajectory after release. If brine is released from an outfall along the seafloor, as is typical, it tends to sink and slowly spread along the ocean floor. Mixing along the ocean floor is much slower than at the surface, thus inhibiting dilution and Ocean discharge is the most common and least expensive disposal method for coastal desalination plants, although this approach can have significant impacts on the marine environment. 35

Mixing brine with waste water may contaminate what is increasingly being considered a new source of water. For this reason, municipal waste water should not be used for brine dilution increasing the risk of ecological damage (Chesher 1975).

Other factors are also important, however. Brine behavior varies according to local conditions (i.e., bottom topography, current velocity, and wave action) and discharge characteristics (i.e., concentration, quantity, and temperature) (Del Bene et al. 1994, Einav and Lokiec 2003). The site specificity of brine behavior suggests that plume models optimized to handle negatively buoyant discharges should be employed to determine the potential marine impacts of all proposed desalination plants.

The chemical constituents and physical behavior of brine discharge pose a threat to marine organisms. Brine can kill organisms on short timescales and may also cause more subtle changes in the community assemblage over longer time periods: “Heat, trace metals, brine, and other toxicants may result in acute mortality to organisms in the receiving water body.

Subtle changes in distribution and abundance patterns and sublethal changes in the physiological, behavioral, and/or reproductive condition of resident organisms may occur” (Brining et al. 1981). Bioaccumulation of toxicants and synergistic effects are also possible.

Certain habitat types, organisms, and organismal life stages are at greater risk than others. Along California’s coast, rocky habitat and kelp beds are particularly rich, sensitive ecosystems, and effort should be made to avoid these areas. Benthic organisms in the immediate vicinity of the discharge pipe are at the greatest risk from the effects of brine discharge. These can include crabs, clams, shrimp, halibut, and ling cod. Some have limited mobility and are unable to move in response to altered conditions. Many

benthic organisms are important ecologically because they link primary producers, such as phytoplankton, with larger consumers (Chesapeake Bay Program 2006). Additionally, juveniles and larvae may also be at greater risk (Cal Am and RBF Consulting 2005).

In 1979, Winters et al. noted the risks that the chemical constituents and physical behavior of brine may pose a threat to the marine environment and stressed the need for adequate monitoring:

It is impossible to determine the extent of ecological changes brought about by some human activity (e.g., desalination) without totally studying the system involved. Ideally such studies should involve a thorough investigation of both the physical and biological components of the environment. These studies should be done over a long period of time. Baseline data should actually be gathered at the site prior to construction for subsequent comparative uses. This will allow for a thorough understanding of the area in its ‘natural’ state. Once the plant is in operation monitoring should be continued on aregular basis for a period of at least one year but preferably for two or three years.

More than 25 years later, however, only a few studies have performed a comprehensive analysis of the effects of brine discharge on the marine environment, particularly on the West Coast of the United States, as noted in Cal Am and RBF Consulting (2005); the majority of studies conducted thus far focus on a limited number of species over a short time period with no baseline data.

The chemical constituents and physical behaviour of brine discharge pose a threat to marine organisms.

More comprehensive studies are needed to adequately identify and mitigate the impacts of brine discharge. A study conducted by Chesher on the biological impacts of a multi-stage flash desalination plant in Key West, Florida in 1975 serves as a good model but is in serious need of updating. Chesher’s thorough analysis included a chemical and physical analysis of the discharge, a historical analysis of sediments to determine the concentration of heavy metals and the abundance of certain fauna over time, and in situ and laboratory biological assessments of a number of organisms. Chesher found that “[a]ll experiments showed the effluent had a pronounced impact on the biological system within Safe Harbor. Even the organisms which were more abundant at Safe Harbor stations than at control stations were adversely affected in the immediate vicinity of the discharge.” Although impacts are site-specific, Chesher’s study suggests that further research and monitoring are necessary and that mitigation may be required.

In their 1993 report on desalination, the CCC also cites a lack of information about the marine impacts of desalination – a problem that has yet to be resolved. The CCC compiled a thorough list of pre- and post-operational data that should be collected to evaluate the marine impacts associated with brine discharge (CCC 1993). Table 8 summarizes these data.

We strongly recommend that this information be acquired for all plants proposing to locate along the California coast before permits are issued.

Desalination Facilities Will Be Vulnerable to Some Climatic Impacts

Desalination facilities are likely to have some special vulnerability to climate impacts. Ocean desalination plants are constructed on the coast and are particularly vulnerable to changes associated with rising sea levels, storm surges, and increased frequency and intensity of extreme weather events. Intake and outfall structures are affected by sea level. Over the expected lifetime of a desalination facility, sea levels could plausibly rise by as much as a foot or more, and storm patterns are also likely to change on a comparable time scale. All of these impacts have the potential to affect desalination plant design and operation and should be evaluated before plant construction and operation is permitted.

Desalination Facilities Exacerbate Climate Change with Their Large Use of Energy

The water sector consumes a tremendous amount of energy to capture, treat, transport, and use water.

The California Energy Commission (2005) estimates that the water sector in California used 19% and 32% of total electricity and natural gas use, respectively, in 2001. Substantial quantities of diesel were also consumed in California’s water sector.

Because desalination is the most energy-intensive source of water, desalination will increase the amount of energy consumed by the water sector.

The currently proposed desalination plants would increase the water elated energy use by 5% over 2001 levels.38

The energy-intensive nature of desalination means that extensive development can contribute to greater dependence on fossil fuels, an increase in greenhouse gas emissions, and a worsening of climate change. We recommend that regulatory agencies consider requiring all new desalination facilities be carbon-neutral – i.e., that the greenhouse gas emissions associated with desalination facilities be offset through energy efficiency improvements, or greenhouse gas emission reductions elsewhere.

While this approach has not yet been adopted for other sectors in California, we recommend that regulatory agencies consider requiring all new desalination facilities be carbon-neutral, it is warranted given the likely significant impacts of climate change on California’s water resources.

Desalination with Alternative Energy Systems Can Reduce Climate Impacts

One way to decouple the impacts of desalination facilities on climate emissions is to power them with non-fossil fuel sources. Desalination optimists have long pointed to the possibility of running desalination plants with alternative energy systems, from solar to nuclear, as a way of reducing costs or dependence on fossil fuels, and more recently, as a way of reducing greenhouse gas emissions and local contributions to climate change. While this discussion continues, there is, as yet, no economic advantage to dedicating alternative energy systems to desalination because of the high costs relative to more-traditional energy systems and the lack of a regulatory agreement to control greenhouse gases.

The barriers to greater use of alternative energy are rarely technical. Solar energy has been used directly for over a century to distil brackish water and seawater. The simplest example of this type of process is the greenhouse solar still, in which saline water is heated and evaporated by incoming solar radiation in a basin on the floor and the water vapour condenses on a sloping glass roof that covers the basin. When commercial plate glass began to be produced toward the end of the 19th century, solar stills were developed. One of the first successful solar systems was built in 1872 in Las Salinas, Chile, an area with very limited fresh water. This still covered 4,500 square meters, operated for 40 years, and produced over 5,000 gallons/d (about 20 m3/d) of fresh water (Delyannis and Delyannis 1984). Variations of this type of solar still have been tested in an effort to increase efficiency, but they all share some major difficulties, including solar collection area requirements, high capital costs, and vulnerability to weather-related damage.

There are examples of desalting units that use more-advanced renewable systems to provide heat or electrical energy. Some modern desalination facilities are now run with electricity produced by wind turbines or photo-voltaics.

An inventory of known wind- and solar-powered desalting plants (Wangnick/GWI 2005) listed around 100 units as of the end of 2004. Most of these are demonstration facilities with capacities smaller than 0.013 MGD (50 m3/d), though a 0.08 MGD (300 m3/d) plant using wind energy was recently built in Cape Verde. The largest renewable energy desalination plant listed by the end of 2005 was a 0.5 MGD (2,000-m3/d) plant in Libya, which was built to use wind energy systems for power. A 0.3 MGD (1,000-m3/d) plant in Libya in the same location was designed to use photovoltaics for energy. Both of these plants went into operation in 1992 and desalted brackish water using RO. No plants run solely with nuclear power have been built, although a few desalination plants supply high-quality water for nuclear facilities (Wangnick/GWI 2005).

Renewable energy systems can be expensive to construct and maintain.

While the principal energy input is free, the capital cost of these systems is still high. As with conventional plants, the final cost of water from these plants depends, in large part, on the cost of energy. A pilot plant combining photovoltaic electricity production with ED operated for a while in Gallup, New Mexico, producing around 800 gallons/d (3 m3/d) of fresh water at a cost of around $11.36/kgal ($3.00/m3) (Price 1999).

At present, this cost is prohibitive for typical water agencies, but these systems may be more economical for remote areas where the cost of bringing in conventional energy sources is very high. If the price of fossil fuels increases or renewable energy costs drop, such systems will look more attractive. Ultimately, these energy systems must prove themselves on the market before any such coupling can become attractive.

Co-Locating Desalination and Energy Facilities

Integrating desalination systems with existing power plants (or building joint facilities) offers a number of possible advantages, including making use of discarded thermal energy from the power plant (co-generation), lower-cost electricity due to off-peak use and avoided power grid transmission costs, and existing intake and outfall structures to obtain seawater and discharge brine. In addition, building on existing sites may prevent impacts at more pristine or controversial locations. Co-location can produce substantial energy and economic advantages and, some argue, reduce environmental impacts. Co-location is common for distillation plants built in the Persian Gulf, was proposed by Poseidon Resources for the Tampa Bay desalination plant, and is being considered for nearly half of the proposed plants in California (Filtration and Separation 2005b). While many of the distillation plants installed in the Middle East and North Africa use co-generation, the proposed co-located plants along the California coast share physical infrastructure like the intake and outfall pipes and are only loosely thermally coupled to the power plant. Under this arrangement, a portion of the power plant cooling water is pumped to the adjacent desalination plant, where it undergoes treatment. Warm water from the power plant requires less energy to remove salts, thereby lowering treatment costs. The brine is then returned to the outfall and diluted with cooling water from the power plant.


Given the type of co-location proposed in California and conditions in California, it is not clear whether the economic advantages of co-location are as substantial as some claim. Since intake and outfall pipelines can be 5% to 20% of the capital cost of a new facility (Voutchkov 2005), collocation can potentially reduce costs by up to 10% (assuming capital costs are 50% of total costs). But savings from co-location may be much smaller, even trivial, depending on the setting. And as noted above, a 25% increase in energy cost would more than offset a 10% savings from co-location. In addition, current state and federal utility laws do not allow desalination plants to obtain below-market rates from an adjacent power plant that sells power to the grid, thus lessening the economic advantages of co-location (CDWR 2003, CPUC 2005).


Co-location may also have drawbacks that require careful review and consideration. Opponents argue that co-location will prolong the life of power plants that use OTC systems. OTC is an inexpensive, simple technology in which seawater is pumped through the heat exchange equipment once and then discharged. These cooling systems impinge and entrain marine organisms and discharge warm water laced with antifouling chemicals into the ocean, resulting in significant environmental


Co-location can produce substantial energy and economic advantages and, some argue, reduce environmental impacts. Co-location may also have drawbacks that require careful review and consideration.


Many of the power plants using OTC systems were constructed prior to 1980, when the marine impacts of this technology were not well understood or regulated. The California Energy Commission recently concluded that “California marine and estuarine environments are in decline and the once-through cooling systems of coastal power plants are contributing to the degradation of our coastal waters” (York and Foster
2005).


The future of OTC systems remains unclear; as a result, the proposed collocated plants face a large degree of uncertainty about future operations. Federal and state agencies, whose regulations cover coastal power plants, including the United States Environmental Protection Agency (U.S. EPA), CCC, California Energy Commission, and State Lands Commission, recognize the problems posed by OTC systems and are pushing for tighter restrictions. For example, the State Lands Commission, which administers and protects public trust lands that underlie navigable waters, adopted a resolution that calls for denying new land leases or extensions of existing land leases for facilities associated with OTC systems after 2020 (CSLC 2006). In addition, U.S. EPA, which regulates cooling water intake structures under section 316(b) of the Clean Water Act, issued new regulations for existing power plants in 2004 requiring them to reduce impingement by 80% to 95% and entrainment by 60% to 90 percent. The U.S. EPA provided a number of compliance options to meet the new 316(b) requirements, such as (1) reducing intake flow to levels similar to those of a closed-cycle cooling system; (2) implementing technology, operational measures, or restoration measures that meet the performance standard; and (3) demonstrating that costs exceed the benefits for that specific site.


A pending lawsuit by River keeper and a number of other organizations may disallow restoration and site-specific benefit-cost analysis as a means of complying with U.S. EPA’s new requirements. In California, SWRCB and the nine RWQCBs administer the U.S. EPA’s regulations on power plant cooling water discharge. Currently statewide policy regulates only the thermal discharge of power plants, whereas the RWQCBs regulate impingement and entrainment associated with cooling water intake structures. This arrangement has led to inconsistent regulation of impingement and entrainment effects across the state. Because of the flexibility in the U.S. EPA’s new 316(b) regulations, however, SWRCB will likely adopt a statewide strategy regulating impingement and entrainment. The statewide policy may be more stringent than the U.S. EPA’s regulations.


Alternative technologies and operational practices may help reduce or eliminate the marine impacts associated with OTC systems, but they also reduce power plant efficiency. York and Foster (2005) concluded that flow reduction and alternative cooling technologies, such as dry cooling and recirculating cooling, are the best options available, as “other entrainment and impingement reduction methods such as changes in intake location or physical or behavioral barriers have not proved to be feasible and/or effective for most power plants.” Further, “EPA’s own figures suggest that mandating recirculating cooling on all plants was highly cost-effective and would result in increased power costs to average residential customers of under a dollar per month” (Clean Air Task Force 2004). Ninety-five percent of the newly licensed power plants since 1996 use alternative cooling technologies (York and Foster 2005).


The future of OTC systems remains unclear; as a result, the proposed co-located plants face a large degree of uncertainty about future operations.


Significant reductions in water flow reduce the desalination plant’s feedwater supply and lead to more concentrated brine discharges. The desalination plant may also occupy the limited real estate needed to install alternative cooling technologies.


Co-location may create a regulatory loophole. It can be argued that the desalination plant will have no impacts above and beyond the OTC system and that any externalities associated with water intake, i.e., impingement and entrainment, are due to the OTC system. Once the desalination plants are built, however, they may then be used to justify continued use of OTC systems and allow the power plant operator to obtain a site-specific 316(b) exemption. Currently a power plant operator can obtain an exemption from the EPA’s 316(b) regulations if he or she can demonstrate that the cost of installing the new technology exceeds the benefits. If the forgone water supply is considered an additional cost of installing an alternative technology, the cost-benefit analysis may favour co-located plants. Thus, allowing desalination plants to piggyback off of power plants using OTC may prolong the life of this technology.


A desalination plant should not be an excuse to continue using an outdated, environmentally damaging technology. In the event that the SWRCB adopts strict OTC regulations, desalination plant operators must plan for the possibility that the co-located power plant will cease operation or reduce water flow significantly. In Huntington Beach, Poseidon has negotiated a contingency plan should the Huntington Beach Generating Station cease operation. If this occurs, Poseidon would have the option to buy the intake and discharge infrastructure but must acquire its own operating permits due to a change in project description (Poseidon Resources 2005a). This contingency, however, does not address the fact that there will no longer be cooling water available for brine dilution.


The EIR for the Carlsbad plant, also submitted by Poseidon Resources, offers no such contingency plan (Poseidon Resources 2005b). Because of the uncertainty associated with OTC systems, the effects of desalination must be assessed independently of the power plant. The California Desalination Task Force’s recommendation suggests that regulatory agencies are moving in this direction: “For proposed desalination facilities co-locating with power plants, analyse the impacts of the desalination facility operations apart from the operations of the co-located facilities. This will identify the impacts of the desalination facility operations when there are reductions in cooling water quantities” (CDWR 2003). The CCC has also adopted this approach.


In addition, co-location requires close coordination between two separate entities, the desalination plant and the power plant, thereby introducing additional uncertainty and cost into building and operating the desalination plant. For example, Cal Am, which is proposing to build a desalination plant at the Duke Energy power plant in Moss Landing, has not yet obtained a county permit to build a pilot plant because Duke Energy failed to comply with county wetland mitigation requirements. Duke Energy, which is now selling the site, was required to submit a wetland management plan and pay a $25,000 bond for removing an oil storage tank from their property. Duke Energy failed to pay the bond and must now update the bond assessment, a process that could take months to


A desalination plant should not be an excuse to continue using an outdated, environmentally damaging technology.

Cal Am officials feel that these delays are unwarranted given constructing the pilot plant will delay project completion.39 The uncertainty about future operations associated with OTC systems and coordination among separate entities suggests that permitting agencies and the public should apply a higher level of scrutiny to co-located desalination plants.

Environmental Justice Considerations

Most of the proposed desalination plants in California are likely to be located in existing industrial areas to take advantage of infrastructure and local resources. Because low-income populations tend to live in these areas, desalinations plants may have a disproportionate impact on these communities. These communities have traditionally borne significant airquality impacts from local facilities, higher exposure to noise and industrial chemicals, and truck traffic. When desalination facilities are built as co-located plants, the on-site energy plant may be forced to operate at a higher capacity or continuously, thereby increasing air-quality impacts.

Local communities may also suffer as a result of the desalination plant’s water-quality impacts; fish may have elevated levels of metals or other toxin, and those who rely on caught fish to supplement their protein intake may be adversely affected. Low-income and people of color may also bear disproportionate effects of increases in water rates (EJCW2005). The Environmental Justice Coalition for Water recommends several principles on environmental justice and water use:

• State legislatures should establish independent reviews of social, economic, and environmental inequities associated with current water rights and management systems.


• There should be independent review of the social and economic impacts of water development on local communities.


• Local public review and approval should be required for any proposal to introduce private control, management, or operation of public water systems.


• All water and land-use projects should be planned, implemented, and managed with participation from impacted community members.


• Actions are required to clean up pollution of water bodies upon which low-income populations rely for subsistence fishing (EJCW 2005).

Perhaps the greatest barrier to desalination remains its high economic cost compared to alternatives, including other sources of supply, improved wastewater reuse, and especially more efficient use and demand management. We do not believe that the economic evaluations of desalination commonly presented to regulators and the public adequately account for the complicated benefits and costs associated with issues of reliability, quality, local control, environmental effects, and impacts on development. In general, significant benefits and costs are often excluded from the costs presented publicly. California should pursue less costly, less environmentally damaging water-supply alternatives first.

Conclusion

Is desalination the ultimate solution to our water problems? No. Is it likely to be a piece of our water management puzzle? Yes. In the end, decisions about desalination developments will revolve around complex evaluations of local circumstances and needs, economics, financing, environmental and social impacts, and available alternatives.

We urge that such decisions be transparent, honest, public, and systematic.

ITG: With reports like this in the public domain why has Mr Holding gone ahead with the desal plants construction when it is obvious that it has critical consequences for the enviroment and the residents that live here ?

Will they only listen when its too late ?

I dont want my family or my enviroment to be unhealthy, so when will this government listen to these reports?....