Synopsis: Morro Bay and Cayucos have come out with a "briefing booklet" for the California Coastal Commission outlining where the joint owners of the wastewater treatment plant are heading with their plans for a new facility. It makes one thing clear: the direction is not where the Commission and its staff have told them to go for almost four years— and where the Commission is certain to redirect them very soon.
Three days ago, on March 28, the city of Morro Bay and the Cayucos Sanitary District issued what they call a "Briefing Booklet" for the California Coastal Commission laying out their final stand on their proposed wastewater treatment plant, a stand that said once and for all they are going to stick with the site of the current plant for a required new one— based on contradictions, falsehoods and omissions that pack the online booklet.
Any hope that the hiring of Dudek engineering to design a plant that would meet the clear requirements of the Coastal Commission, its staff, the Coastal Act and the city's own Local Coastal Plan were dashed once and for all by the "CCC Briefing Booklet :Wastewater Treatment Plant Upgrade Briefing.
On March 11, 2011, the Commission took control of the wastewater treatment plant (WWTP) planning process after rejecting virtually the same proposal contained in the Briefing Booklet: build a new plant where the old one now stands. And now, it seems beyond doubt that the Commission and its staff will ignore the last shot of Morro Bay and Cayucos (MB/CSD) to lay out what must be built to meet statutory requirements and the needs of residents in Morro Bay, if not Cayucos. (Whether the CSD withdraws from its joint ownership and partnership with Morro Bay is up in the air.)
One big omission from the booklet is the author. Is it Dudek or the MB/CSD staffs?
Following are fundamental flaws in the booklet.
Contradictions:
— Recycled water feasibility not a distinguishing factor in treatment plant siting. The just released Dudek recycling water feasibility study (see below) states that a new plant at the old site could not produce water feasibly and at an economic cost.
— "Based on the analysis contained herein, it is therefore recommended that the current WWTP be brought back before the CCC during its de novo review hearing as the most feasible alternative site for development of the MB/CSD’s WWTP facilities in accordance with its consistency with applicable City LCP (Local Coastal Plan) and CCA (California Coastal Act) policies, its ability to reduce environmental impacts to a less than significant level, and because it presents the most streamlined project implementation schedule, while being the most cost‐effective option for the rate payer within the MBCSD service area." The Coastal Commission has already stated clearly that building a new plant at the present site is inconsistent with the LCP and Coastal Act because the site is in 100-year flood and tsunami hazard zones, it would interfere with Coastal Act protections of coastal views and public access, and there is no evidence that the present site would be most cost-effective to build on— even if the site were statutorily acceptable, which the Commission has said it is not.
Falsehoods:
— Seventeen sites for a new plant were initially reviewed starting after the Coastal Commission rejected the current plant site and six were dismissed due to fatal flaws. Those flaws were never documented.
— The present plant, Chevron and Righetti sites all could accommodate recycled water "when determined to be economically feasible." Dudek's own recycling study has found that recycling water at the present site would not be feasible (see below). No evidence has been provided in this regard about the other two sites.
— There is low tsunami potential at the current WWTP site; In the 100-year floodplain, the project reduces facility footprint by 50% (compared to the present site), mitigation feasible to reduce risk, facility improvements not affected by long‐term shoreline erosion, storm surge or wave run‐up, or sea level rise for a 100‐year time period (well beyond design life of project). The Coastal Commission has found otherwise, and MB/CSD have presented no acceptable evidence to the contrary.
Omissions:
— The cost of a new plant at the present site would be about $61 million, on the Chevron site (where Morro Bay and Cayucos borders meet) $105 million and on the Righetti property (several miles east on Highway 41) $89 million. No evidence of those figures are provided or have been in previous reports.
— Anticipated project completion dates are December, 2015, for the present site; March, 2023, for the Chevron site, and April, 2022, for the Righetti property. No evidence of how those dates were reached were provided.
— The site of the current plant can be found consistent with the city's LCP and Coastal Act policies related to coastal hazards, public access and recreation, visual resources,
archaeological resources and sustainability/water reclamation. The Coastal Commission has ruled it cannot be found consistent on any of those counts and the Dudek report agrees (see blow).
Here are recommendations in the booklet to the Coastal Commission:
— MB/CSD should continue with proposed project to upgrade to full disinfected secondary treatment in accordance with the settlement agreement with RWQCB (Regional Water Quality Control Board. (The Dudek report found it is not economically feasible.)
— Immediately implement recycled water use within the WWTP site. (The Commission and its staff have found a very inadequate supply would be produced.)
— Pursue expansion of recycled water system to areas immediately surrounding the WWTP. (Unclear.)
— City should collaborate with other stakeholders to develop a regional salt & nutrient management plan. (No explanation.)
— Explore opportunities to serve Morro Bay Golf Course water in exchange for reduced pumping of existing non-potable well water. (Unclear.)
— Continue to investigate funding programs that may help offset high costs of recycled water project implementation. (Unclear.)
— Continue with current, pro-active, multi-faceted water conservation program. (No evidence that it is effective.)
— Review and update water supply and demand data as part of routine Urban Water Management Plan (UWMP) preparation. (Unclear and not explained elsewhere.)
Meanwhile, a key new study has been conducted by the engineering consultant that is involved in planning a new wastewater treatment plant for Morro Bay and Cayucos to determine the feasibility of the new plant producing significant amounts of recycled water — water that would not only replace unreliable state water but could save residents significant amounts of money on their water rates. Except one thing: the study was done incorrectly.
Would it be feasible for a new Morro Bay-Cayucos wastewater treatment plant to produce all kinds and large amounts of recycled, cleansed, and disinfected water for residential irrigation, local commercial farming, and even potable use — washing, showering, and drinking in homes?
Those, all rolled into one, is the overriding question that still looms in the planning for a new jointly-owned and operated Morro Bay-Cayucos wastewater treatment plant (WWTP), planning that was prompted in 1999 when state authorities ruled that the old, existing plant was no longer meeting state water standards. The present plant dates back to 1951, city records show.
The California Coastal Commission (CCC) ordered the city of Morro Bay and the Cayucos Sanitary District (MB/CSD) to undertake a study to answer that feasibility question and help determine the design, function, capacity, and possible location of a new plant to produce recycled water. The CCC issued that order on March 11, 2011, when it rejected the MB/CSD proposal to upgrade the old, existing plant at the same location on the shores of Estero Bay just south of Morro Bay High School.
Two months ago, in January, MB/CSD was thought to have instructed its engineering firm, Dudek, to conduct a study — at an additional cost of $110,000 — to answer that question for the CCC. On March 9, Dudek produced a "Draft 2012 Recycled Water Feasibility Study." In addition, on March 8, MB/CSD issued a call for the public to submit comments about the study through April 4.
But wait a minute — something is wrong here!
What plant did the CCC envision being studied — the upgrade of the old, existing plant that MB/CSD originally proposed in January, 2011? That proposal was rejected by the Commission on March 11, 2011, so the CCC wouldn't ask for a recycled water study for a plant it has already eliminated, would it?
Or would the CCC be seeking a study of recycled water that could be produced by a possible new plant at sites somewhere else, which the CCC envisioned in its decision on March 11, 2011?
So which plant did Dudek conduct its study on — the old one or a new one?
After combing through the 162-page Dudek study and CCC statements on the WWTP project, two things are clear:
1. The Commission wants the study done on a new plant, not an upgrade of the old plant. "The Applicant (MB/CSD) must also provide a complementary, updated water reclamation feasibility study that explores all potential demand for reclaimed water, including for agricultural irrigation inside and outside of the City limits, and the way in which the project could be reconceived to dispose of treated effluent in this manner."
The Commission obviously was saying that the proposed project submitted by MB/CSD had to be reconceived — revised, as evidenced by the long list of things the Commission found unacceptable about what MB/CSD had submitted. Lest there be any doubt about recycled water being a top priority, the CCC staff told MB/CSD in 2010 that the city's "LCP (Local Coastal Plan) clearly requires the City to pursue water reclamation as part of this WWTP project."
Then, last December, the Commission staff specified what it wanted MB/CSD to provide in that study, as a followup to what the Commission had already ordered generally on March 11. The staff said the study should determine the cost and feasibility of a plant providing significant amounts of recycled water from any one of the possible new 17 plant sites that have been under review for more than a year.
2. But Dudek did not conduct a study of developing recycled water at a plant at other sites but at the existing plant that MB/CSD proposed to the Commission and was rejected. (The Dudek study uses a number of different terms for the WWTP project at the center of its study but, "upgrade" is the term that MB/CSD have been using throughout the planning process to refer to building a new plant where the old one now stands, despite the fact the CCC has insisted that it is not an upgrade but a brand new project. Upgrade was mentioned 70 times in the study, and "the existing plant" also was referenced, the meaning of which is obvious.)
Conducting the recycled water study on the existing plant raises the question: was $110,000 wasted by MB/CSD in either allowing or ordering the study to be conducted by Dudek on that site, which the CCC has made abundanly clear is passe in the planning process?
And what did Dudek conclude about producing the quality and volume of recycled water, which the Commission has called for, at an "upgraded" existing plant? Not feasible — primarily because of cost and lack of demand, a finding that seems meaningless because the existing plant site is no longer under consideration for construction of a new WWTP by the CCC, which now has full control over the project.
Last December, the CCC staff made a specific request to the MB/CSD for a broad range of information about the feasibility of recycled water being produced by plants at the potential sites under consideration — but not an upgraded plant at the present location because the Commission has gone on at length about why that site is unacceptable, mainly because it is in 100-flood and tsunami hazard zones, an area the city's own Local Coastal Plan, which Morro Bay must follow in administering its coastal area and which the Commission oversees, prohibits a new plant being built — or upgraded — in.
But that isn't all. The Dudek report is marked by errors, important missing information, apparently false assumptions, and confusion at times.
The error that stands out is the report's claim that water that the city now receives from the State Water Project is the city's top priority as the source of water the community depends on. The Dudek report said: " . . . the City’s Local Coastal Program (LCP) identifies the use of recycled water as the City’s second highest priority (behind State Water Project water)."
But, the Commission staff quotes the LCP as stating that "even with the delivery of state water, use of reclaimed water is the City’s second highest priority [after conservation] and remains a productive source of potential conservation for both large and small scale projects . . . . "
By Dudek (falsely) claiming that state water is the LCP's top priority, it serves to make local recycled water seem of much less importance than the CCC and its staff place on it.
The reason that the CCC and its staff believe so strongly that a new plant must be designed to produce large amounts of top-quality recycled water is because "maximum reuse of reclaimed water would help the City meet its water supply needs and ensure water supply is available for priority uses as required by the LCP, especially if/when State Water is restricted or unavailable."
The CCC also pointed out that "the reliability of State Water has decreased due to judicial decisions regarding endangered fish species and concerns about global warming. In addition, the use of State Water is extremely energy intensive and has significant environmental impacts far removed from Morro Bay, including impacts on anadromous fish and other species in the Delta. These, and other, State water concerns highlight the general issue associated with ensuring that appropriate measures are taken to move towards and ensure a locally sustainable water supply."
In addition, the CCC said, a plant that is able to provide "a new supply of reclaimed water in a community where the existing water supply is not sustainable and water shortages are frequent" would be invaluable. And, the CCC staff has added, it probably will be less costly to water-users in Morro Bay than state water, which is notoriously expensive.
By contrast, the Dudek report makes no mention of the growing questions about the reliability of state water due to changing weather conditions, dwindling supplies of water in the mountains and rivers and calls for greater conservation by local agencies. The Dudek report states that the State Water Project "ensures reliable high‐quality, potable water supply to the region," and "the City of Morro Bay has adequate, reliable supplies to meet projected demands," without documenting either claim.
In a 2010 report, the Association of California Water Agencies said, "Climate change, levee vulnerability and restrictions to protect endangered fish species will continue to affect the reliability of State Water Project deliveries for the foreseeable future, according to a new report by the Department of Water Resources." That Department stated that it "predicts continued erosion of SWP (State Water Project) water delivery reliability under the current method of moving water through the (Sacramento-San Joaquin River) Delta."
The Dudek report also says that "ocean monitoring over the last two decades (1990‐1999) has shown no negative environmental impact associated with the discharge [Carollo, 1999]," even though 1990-1999 is not two decades.
At one point, the study states that "over the past decade, MBCSD has proactively shored up its water supply portfolio and resource management strategy. Several significant water users have been converted to non‐potable sources, thereby reducing potable water demand but making them less likely to convert to recycled water." The assumption is not explained: why wouldn't such users rather be served with recycled water of a higher quality and possibly less costly than non-potable water?
The study also says that "the potential recycled water users are largely unchanged from previous studies" and referred to "an updated market assessment of potential recycled water customers in the Morro Bay and Cayucos area." The statement is apparently based on a recent survey of potential water users in Morro Bay, which has been called into serious question. (See: Slo Coast Journal - November 2011).
The bottom line is that MB/CSD are no nearer to providing the data that the CCC requested about the feasibility of producing and making available high-quality recycled water from a new WWTP — at a location somewhere other than where the existing one stands. And that can only cause more days in building a new WWTP.
