Synopsis: The California Coastal Commission staff has once again rejected proposals for a new Morro Bay-Cayucos wastewater treatment plant, calling for extensive additional information about the seventeen sites under review as a location for the new plant, information that apparently points to the staff ultimately requiring a facility that would produce significant quantities of recycled water and provide a new, cheaper and more reliable source of household water.
For the second time in less than a year, the California Coastal Commission staff has rejected planning proposals by Morro Bay and the Cayucos Sanitary District for a new jointly-owned and operated wastewater treatment plant, apparently pointing the way for the Commission ultimately to require a facility that would produce vast amounts of disinfected recycled water that could provide Morro Bay, if not Cayucos, with a new, cheaper, safer, and much more reliable source of household water than it has had in many years. The Commission has the authority to do just that.
Instead of sending the proposed outlines for a new plant to the Coastal Commission for consideration of final approval, which was the other option, thereby probably clearing the way for construction to begin soon, the Commission staff sent them back to Morro Bay City Council and the Cayucos Sanitary District board (MB/CSD) for additional, significant data, an action that, in effect, rejected what was provided by MB/CSD as incomplete and unacceptable.
The additional information the Commission staff is requiring (as reported to the Journal by the Commission staff) consists of:
— The cost and feasibility of a plant providing significant amounts of recycled water from any one of the 17 plant sites that have been under review for more than a year,
— A comparative analysis of other plant projects using recycled water, like Baywood-Los Osos and Monterey,
— The costs of recycled water from a new plant if spread among not only present users of city water in Morro Bay, if not Cayucos, but also landowners who are not yet customers,
— A review of the most "most practical, strategic and cost-effective" location of a facility for injecting recycled water into underground aquifers that city wells would draw drinking water from, and
— An estimate of the yield of recycled water from a plant that is approved for construction and how many people now use water from city wells and how much is being used.
It seems clear the Commission staff is headed toward recycled water as the priority for a new plant, which might be more appropriately called a new water reclamation facility.
All these information requests grew out of a meeting among the Commission and MB/CSD staffs on December 9 in Santa Cruz where the Commission staff reacted to the MB/CSD's latest proposals for a new plant, which still ranks the current plant site on the shores of Estero Bay as the top location choice, despite the fact the Commission staff in no uncertain words as far back as last February (Slo Coast Journal - March 2011) has said it is unacceptable because of its exposure to 100-flood and tsunami threats.
A MB/CSD report on that December 9 meeting (MB/CSD Staff Report) sounds as if nothing significant took place. "CCC staff stated that the process is smooth thus far," the MB/CSD report says. "The CCC staff stated they believe the majority of their issues and additional information needs have now been identified." Not only does this assessment conflict sharply with the information obtained from the CCC staff by the Journal, but it is partly in error.
Rather than the Commission staff believing that "the majority of their issues and additional information needs have now been identified," the Commission staff requested significant new amounts of information that was not contained in the 230-page Alternative Sites Evaluation Phase 2— Fine Screening Analysis prepared by Dudek engineering under a $360,000 contract with MB/CSD. That analysis was submitted to the Commission staff as an overall plan for what was being outlined as the basics for a new plant.
Both the Commission and MB/CSD staffs agreed to try to meet again in early February to review the requested information that MB/CSD may provide by then. And they also agreed to tentatively plan for what is called a de novo hearing— where the Coastal Commission could make a final decision on a new plant— next April 12 in Ventura. But it all depends on the adequacy of the information that MB/CSD in the meantime will provide to the Commission staff, which made clear that if what is submitted by MB/CSD is not adequate by the planned February meeting, it appears very unlikely that the de novo hearing will be possible in April.
Project manager Dennis Delzeit said a MB/CSD meeting under their Joint Powers Agreement (JPA) is being planned for mid-January to review his report on the December 9 meeting. No date or location of the JPA meeting was announced as of the last city staff working day in 2011, December 30. Also, a staff member had said Delzeit's report would be released to the public, but it hadn't as of December 30, two weeks after it was distributed to the city council and the Journal.
There is nothing new about the Commission staff making clear that large volumes of recycled water must be one of the essential requirements of a new plant.
The Coastal Commission has stated flatly that Morro Bay's own Local Coastal Plan (LCP) "clearly requires the City to pursue water reclamation as part of this WWTP (wastewater treatment plant) project." A November 12, 2010, letter from the Commission staff to MB/CSD outlining the requirements of a new plant said "details about the potential to reclaim 100% of the wastewater produced" by a new plant must be provided by MB/CSD. But it hasn't, as the Commission staff found once again at its meeting with the MB/CSD staffs on December 9.
MB/CSD are on record rejecting widespread use of recycled water for their water customers' needs. "Both the City of Morro Bay and Cayucos were previously evaluated for potential users of recycled water by Carollo Engineers in 1999 as part of the Comprehensive Recycled Water Study. That study concluded that implementation of a full-scale reclaimed water program was economically infeasible." (Slo Coast Journal - October 2011). Note that conclusion was based on a 12-year-old study when groundwater supplies in Morro Bay were much more plentiful and state water was cheaper and its reliability was assumed, a far cry from the present situation involving state water, as the Coastal Commission staff has repeatedly emphasized.
Why would Morro Bay be opposed to providing recycled water for use by residents, almost certainly saving them significant amounts of money in rates? Perhaps it is because Robert Enns, president of the CSD board, has publicly stated at a MB/CSD meeting earlier this year that Cayucos doesn't need recycled water and doesn't want to help build a plant with capacity to produce it. Cayucos gets its water from several private water companies, whose wells are fed indirectly by the Whale Rock Reservoir there. If recycled water from a new plant would provide Cayucos residents with cheaper water, would the CSD consider it? There has been no hint of that ever being asked, at least in public.
Or is it because the city of Morro Bay is worried that the CSD will pull out of its JPA partnership, which reportedly has been discussed within the CSD? The two elected bodies were engaged in revising and updating their JPA agreement last year when the planning for the plant was beginning to be finalized with the authorization of an Environmental Impact Report. And suddenly the revision was dropped for no apparent or stated reason.
The Commission staff made a number of other requests for information at the December 9 meeting, which included:
— Visual simulations of the 17 alternative sites reviewed in the Dudek evaluations to help provide the highest and best use analysis of each site in terms of environmental appearance and acceptability as possibly related to capital costs.
— Additional information on the tsunami analysis in the Dudek report, which the Commission staff said did not provide the final word on this issue. The staff said it has met with its technical staff and determined current maps of the tsunami zones are needed to provide estimates of the potential for flooding of several possible plant sites, including the current plant area.
— An up to date flood analysis of the sites. The Federal Emergency Management Agency (FEMA) maps of areas with sites in danger of flooding that are provided in the Dudek report fail to provide the most current evidence of future ocean level rises.
— More information on alternative options for disposal of any unneeded processed water from any proposed site.
