The California Coastal Commission staff has recommended that no new Morro Bay/Cayucos wastewater treatment plant can be built where the present one is located, has designated where the plant must be built and has outlined the capacity of such a plant to produce an abundant supply of cleansed water for a wide variety of valuable uses by the two communities. The Commission on August 9 is expected to approve those recommendations at its meeting in Santa Cruz, ending years of futile efforts by Morro Bay and Cayucos to avoid the clear and often-stated requirements of the Commission staff for development of a new plant.
The Morro Bay/Cayucos wastewater treatment plant saga is all but over — with only one surprise.
The California Coastal Commission staff, in its final report capping years of struggle with Morro Bay and the Cayucos Sanitary District (MB/CSD), has recommended that (1) a state-required new wastewater treatment plant (WWTP) cannot be built where the present one is located on the shore of Estero Bay, as advocated by MB/CSD, (2) it must be built on the Righetti property east of the city off of Highway 41 at the city/county border and (3) it must be a plant with capacity to produce large quantities of recycled water that can be used to provide the city with a new, reliable and much more affordable supply of water for residents. Despite the false information put out by MB/CSD, state reports show the city's present dependence on state water as a primary source of its water is highly unreliable and extremely costly.
The surprise is that to build the plant on the Righetti property would cost a fraction of what MB/CSD claims it would. More MB/CSD misinformation.
The staff report is expected to be approved by the Commission at its meeting on Thursday, August 9, at the Santa Cruz County Board of Supervisors Chambers, 701 Ocean Street, in Santa Cruz. The meeting is scheduled to begin at 9 a.m. on that day, but the MB/CSD item is last on the list of agenda items so isn't expected to be considered until later in the day. The agenda item can be read at Application No. A-3-MRB-11-001 (City of Morro Bay and Cayucos Community Services District).
All this was clearly predictable.
Starting in 2008, the Coastal Commission staff (CCC) informed the city of Morro Bay and the Cayucos Sanitary District — who own and operate the present WWTP and would presumably do the same with a new one — what would be required to authorize a new wastewater treatment plant, which they would develop jointly. One thing was clear: upgrading the 50-plus-year-old existing plant on the shore of Estero Bay would not qualify because it fails blatantly to conform to requirements of the Coastal Act and the city's Local Coastal Plan (LCP), which together give the Commission clear authority to decide where a new plant will be built, what its functional capacity will be, and whether it will provide the water that the two communities need.
Then, in 2010, the Commission staff spelled all that out again. Still, Morro Bay and Cayucos (MB/CSD) kept spending (wasting, actually) money by hiring contractors to argue their case for upgrading the old existing plant. It was as if MB/CSD couldn't or didn't want to get the clear message from the CCC staff's communications.
The Slo Coast Journal over many months has described all this, showing how what the CCC staff has stated is clearly required in a new WWTP completely fails to qualify a plant upgrade of the present plant (See: July 2012 - Upgrading the Existing MB Sewer Plant is Dead, July 2012 - Coastal Commission Ready to Define New Wastewater Treatment Plant, May 2012 - MB/CSD Sewer Plant Project: What's Next?, April 2012 - Newsflash from Morro Bay: Contradictions, Falsehoods, Omissions, and January 2012 - Two Strikes: MB/CSD Sewer Plant Plans)
Why is such an upgrade out of the question? Because it would violate the Coastal Act and the LCP by blocking scenic views and building an industrial facility in a coastal area that must be reserved for visitor-serving uses. The Coastal Act and LCP couldn't be clearer, and the two CCC staff letters to MB/CSD laid all that out explicitly.
Here is how the final CCC report put it:
"The LCP requires the scenic and visual qualities of the coast to be protected and where feasible enhanced, and requires development to be sited and designed to protect views to and along the ocean and other coastal areas. The new WWTP would be in a similar location as the plant to be demolished, but would be larger and taller, including to be elevated above flood levels, degrading as opposed to enhancing the shoreline viewshed, inconsistent with the LCP on this point as well."
That is the fait accompli for a plant upgrade at the present site. But there are other problems with the site, the CCC staff report said.
"The WWTP site is located in a tsunami run-up zone in an area that would also be inundated in a 100-year storm event through a combination of inland flooding (associated with Morro Creek) and ocean flooding, all of which would be exacerbated by sea-level rise over time. The LCP prohibits development in such 100-year flood areas, and the new WWTP cannot be found consistent with the LCP on this point." MB/CSD denied the site would be subject to ocean flooding without any evidence.
The present WWTP and surrounding area, the report said, are perfect for required Coastal Act and LCP uses.
"The WWTP site includes some higher priority visitor-serving recreational uses (i.e., an RV park adjacent to the site). More importantly, this is exactly the type of ocean-fronting land that the Coastal Act and the LCP prioritize for public visitor-serving and coastal recreational uses, and not for low priority industrial use. These kinds of ocean-fronting areas are finite, especially when they are publicly owned, and especially when they are located within developed urban areas such as the City of Morro Bay.
"The WWTP is also uniquely situated in an area near Morro Rock and the Morro Bay Embarcadero — significant visitor destinations — where its potential for recreational use is both enhanced and clearly underutilized, including connecting the Embarcadero area to the portions of the city upcoast of Morro Creek. The WWTP project would site significant industrial development in an area the Coastal Act and LCP prioritize for visitor-serving and public recreational use, further inconsistent with the Coastal Act's access and recreation policies and the LCP."
The present WWTP was built about 20 years before the Coastal Act was approved by the state Legislature in 1976, otherwise it never would have been allowed to be built.
But there is another huge issue involving the capacity of the proposed WWTP to produce tertiary water from effluent. The WWTP plant proposed by MB/CSD would produce a fraction of the cleansed water that the Coastal Act and LCP requires. In fact, the report said, it is the "City's conclusion that it does not need to pursue recycled water because 'the City has no water supply concerns.' "
"The (MB/CSD proposed) WWTP project would produce tertiary treated wastewater, but it only includes a very modest reclamation component, one that is designed to use onsite (and for no other use) only a portion of the reclaimed water that could potentially be produced. The vast majority of the treated wastewater would be discharged to the ocean." As the CCC report makes clear, this is a complete waste of water that could be used for valuable and productive purposes, as required by the Coastal Act and the LCP.
"Read as a whole," the CCC report said, "the LCP thus directs a WWTP project to maximize reclamation so that such recycled water can be made available to both offset potable water use as well as to enhance freshwater resources (e.g., through use for agricultural irrigation, urban landscaping, groundwater replenishment, etc.), especially given that the city receives much of its water from the State Water Project, and reclamation would provide an important contingency in the event that such water transfers are suspended, reduced, or otherwise impacted (e.g., increase in costs, etc.)." Some state reports say that the availability of state water for community use throughout the state has numbered days.
MB/CSD also are under a Regional Water Quality Control Board (RWQCB) order to upgrade the plant's water-producing capacity so that all effluent is treated to at least secondary levels, something that the present plant is far from capable of doing and which the proposed upgrade couldn't come close to achieving.
CCC staff "believes that the Righetti site, located just out of town on the Highway 41 corridor, represents the most viable option for a new WWTP that can avoid the significant issues with the existing site, and that can provide the most opportunity moving forward for maximizing beneficial recycled water reuse as required by the LCP."
The Righetti property is located in county area, the CCC staff report said, and the CCC staff is working with county and RWQCB to facilitate its acquiisition as a site for a new WWTP.
The CCC report said the Righetti site is approximately 260 acres, 11 of which are located adjacent to Morro Bay city limits and north of Highway 41. The western boundary of the Righetti site is located just east of the boundary of the developed, residential areas of the city. Currently the site consists of a single-family residence and grazing areas. The land is surrounded by cropland to the south, undeveloped areas to the north and east, and a mobile home park and agricultural lands to the east. The report said the property would be entirely out of the flood zones, away from any potential sites of archeological significance, away from riparian vegetation buffers, and in an area of relatively gentle slopes.
MB/CSD has claimed that that "an alternative project at the Righetti site would cost approximately $25 million more than a new WWTP at the current plant site," the CCC report said. But the report maintains it would actually cost a fraction of that.
The report said the Righetti site is on the market for $2.4 million and an analysis referred to by the report identifies a property acquisition cost of $7.5 million.
Therefore, "the expense of moving to an alternative site, as opposed to constructing a new WWTP at the current location (even if it were acceptable, which it isn't), diminishes to negligible when other factors are considered, including with respect to reduced costs associated with water reuse at the alternative site, and the potential revenue the City could earn/accrue if the existing WWTP site is used for public visitor-serving uses."
In other words, MB/CSD could— and likely will— receive millions in returns from a WWTP that will produce enough recycled water that could be used to regenerate the city's wells and produce millions of gallons of potable, disinfected water for use throughout the community, including as tap water. Not to speak of the income from developing visitor-serving facilities in the area where the present plant is located — and will be removed.
The Chevron site at the Highway 1 boundary between Morro Bay and Cayucos also was considered as a site for the new WWTP, but the staff report said: "There are significant hazards at this site, including a high landslide potential throughout the site, and significant geotechnical mitigation would be required for the proposed development.
"The site is also highly visible from Highway 1. It is also highly constrained by the potential ESHA (Environmentally Sensitive Habitat Area) impacts because the area is designated critical habitat for steelhead and redlegged frog, both federally listed protected species. Toro Creek, which runs along the northern edge of the property, is also potential habitat for the listed species tidewater goby. Finally, the beneficial reuse of reclaimed water would be highly constrained at this location because it is remotely located from all potential service areas.
"The proposed WWTP is a major public works project and investment in community infrastructure that relies heavily on a conclusion that water supplies are stable, though the city's water supply has many constraints that range from availability and reliability of State Water, the use of an unpermitted, expensive desalinization plant, the overuse and contamination of them, Morro and Chorro groundwater aquifers and the threats to stream levels in the groundwater basins associated with Morro and Chorro Creeks. Regardless of the questions regarding the (MB/CSD's) conclusions regarding water availability, the LCP identifies use of recycled water as the City's second highest priority, it requires recycled use as part of a new WWTP, and use of such recycled water could benefit ESHA and biological resources and reduce the adverse impacts of the project on marine resources, by reducing, or possibly eliminating, the project's reliance on an ocean outfall."
