March 27, 2007.

Dear Superintendent Brian O'Neil, National Park Service, Golden Gate National Recreation Area:

Thank you for your response to the questions we raised about the environmental, health and safety issues of the new operator of the Alcatraz Ferry Service. We "took your statement about facts being misrepresented very seriously and spent the last month verifying several points that you raised in out offices. After doing so, we remain concerned over the National Park Service's ability to objectively evaluate the safety and environmental performance of the new Alcatraz Ferry Service. Regrettably, your letter did not show us that the National Park Service (NPS) conducted a thorough investigation of the reported sewage incidents. We will continue to ask for independent investigations by the Regional Water Quality Control Board (RWQCB) and other enforcement agencies like the US Coast Guard.

In our initial letter, we cited October 13[, 2006] as the date of an alleged sewage spill based on the Ca1/EPA complaint. Your letter disputes the reported October 13 sewage spill at Alcatraz Island by informing us that it was a leak from a saltwater line and not sewage. This claim is supported by the February 7, 2007 statement from Facilities Manager, Mr. Jim Adams. However, there is a discrepancy in the dates between Mr. Adams' statements, which refers October 17 as the date of the saltwater spill, not October 12 as documented in The log by Mr. Cooke right after the incident occurred on October 13 as cited in the Cal/EPA complaint. Your letter also omits any reference to the "Dock Office Log Book" of the Golden Gate National Parks Conservancy (GGNPC) staff which documents sewage spills on October 9 & 12. Mr. Dan Cooke, the GGNPC Educator/Historical Interpreter on Alcatraz Island, documented the October 12, 2006 spill as follows:

"Sewage spill on dock approx 16:30 (4:30 p.m). Alcatraz Cruises Staff hose down area - flush waste into bay."

According to Mr. Cooke, GGNPC staff and NPS did not interview or follow-up with him about his entries or the circumstances that led him to report it. He was not even contacted after the sewage spill incidents were covered in the local press. Mr. Cooke also claims that there were several people that observed the October 12, 2006 incident. Your letter doesn't specify that NPS spoke with other witnesses from Alcatraz Cruises, NPS Rangers and other GGNPC staff. As of this date, Captain Jack Goldthotpe, who filed the Cal/EPA complaint, has not been interviewed by NPS of any other public enforcement agencies.

In addition, we were surprised to learn that the National Park Conservancy recently terminated Mr. Cooke's employment and that he filed a claim with the U.S. Department of Labor for unlawful termination in violation of the whistleblower provisions of the Federal Water Pollution Control Act. Mr. Cooke's claim of retaliation for revealing information about problems with the storage and transportation of sewage from Alcatraz Island is very serious and one that our offices will closely monitor. It further validates the need for an independent. investigation by the RWQCB.

You(r) letter relies on information provided by Alcatraz Cruises that Brelje and Race Laboratories did nor test bilge for E-Coli contamination, putting into question the credibility of the lab that tested a sample for [San Francisco Bay Area IBU Regional Director] Ms. Secchitano. According to the Lab Manager, Ms. Ann Hill, this information is incorrect. Attached is a copy Ms. Hill's March, 14, 2007 letter to you which clarifies the conversations as follows:

"We did not tell Alcatraz Cruises that this was not the type of testing we do. I talked with them and told them we did not collect o(r) pick up samples that far away. . . I did tell them that we could not send a vehicle and person down to San Franco to collect samples."

Ms. Hill submitted a long list of her lab's accreditation with her letter which includes certification for wastewater which includes bilge.

For clarification, Ms. Secchitano never claimed to have personally collected the samples from the bilge On the M/V Islander and our offices have been assured that this assumption in your letter is incorrect. The letter also made mention that Alcatraz Cruises is performing testing of potable and black water with their laboratory. We are glad that Alcatraz Cruises has chosen to perform these tests. We welcome independent analysis of their findings by the United Sates Coast Guard and other public agencies with the technical expertise to evaluate them. Our objective is to ensure the protection of the Bay's ecosystem and the health and safety of passengers and crew by verifying that there is no risk from sewage overflow from the vessels' toilets or contamination in the bilge.

You justified Alcatraz Cruises' refusal to hire a number of the previous concessionaire's employees by stating that the company has a higher competency standard in their deck operation by requiring Senior Deckhands to carry a USCG 100GT Master's license, the same license requited of the Captains. We respect a company's prerogative to set qualifications for its employees. But in this instance, the licensing requirement disqualified highly skilled and experienced senior deckhands for the same duties that they performed with the prior company.

We've learned that the pre-requisite for a senior deckhand to take the licensing test in 380 days of sea time experience. By comparison, most of the deckhands that worked for Blue and Gold had over ten years of sea time experience. Most of the senior deckhands that applied for the jobs were trained by Blue and Gold to land the ferry in an emergency, possess a USCG Able Bodied Qualified Certification and are qualified on high speed ferries operating on routes with greater risks than the Alcatraz Ferry route.

If safety was the primary factor for imposing a higher competency standard, Alcatraz Cruises could have hired Inlandboatmen's Union (IBU) senior deckhands and required them to obtain their 100GT certification as a condition of maintaining employment. This may have provided the optimal situation for both the company and the IBU senior deckhands, who have years of proven experience.

Again thank you for your time and interest and please contact Nick Hardeman in Assemblywoman Fiona Ma's office if you require additional information.

Sincerely,

Assemblywoman Fiona Ma, 12th District

Assemblyman Mark Leno, 13th District

Cc: Speaker Nancy L Pelosi

Supervisor Aaron Peskin

Mr. Bruce Wolfe, San Francisco Bay Regional Qater Quality Control Board

Director Monique Moyer, Port of San Francisco

Read this letter as a PDF File [0].

Read Superintendent O'Neal's original letter PDF File [0].

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