Al Barrow Adds His Comments To The RWQCB’s Stealth Basin Update
Understand the CSD has also added about a gazillion pages of comments. I’ll try to attach Barry Tolle’s comments from the County, if I can get the document to cooperate. Now, the only question: Is anybody listening?
Sorrel Marks and Howard Kolb RWQCB3
Subject: Basin Plan Update/Amendment and Onsite Treatment systems Management
From: Al Barrow Coalition for Low Income Housing and Citizens for Affordable and Safe Environment
Timing requirement of 48 is not realistic or reasonable. For several reasons:
Scheduling a site inspection by repair or pumpers often takes days.
If it is determined a replacement is necesary permit applications may take weeks
WASTEWATER MANAGEMENT PLAN FOR THE SAN LORENZO RIVER WATERSHED: County of Santa Cruz Health Service Agency is included by reference.Environmental Health Service February 1995 249 pages was an example of the testing, research and work task that was done for one area of the county. The tack was expensive and time consuming. Certainly rising to the impact level of an EIR CEQA.:
Letter from Barry Tolle, enclosed with Al’s letter:
What remains so puzzling, given some of the problems outlined by Mr. Tolle’s letter, is that, so far as I know, the county never notified onsite permit holders throughout the county that this stealth update was underway, didn’t hold any hearings, send out postcards, have a BOS agendized meeting on it, zip. Neither did the RWQCB, even though all septic tank owners ARE the stakeholders here. Or should I say Clueless stakeholders?
Sorrell Marks April 7, 2008
Sanitary Engineering Associate
Central Coast Waterboards
895 Aerovista Place Suite 101
San Luis Obispo, Ca. 93401-7906
RE: Comments on Basin Plan Revision
Thank you for the opportunity to make comments on the latest draft of the Basin Plan. San Luis Obispo County has several serious concerns regarding the proposed plan. Many of the requirements require a large financial burden on the part of the County and property owners for conformance.
1. Section VIII.D1b. ONSITE WASTEWATER MANAGEMENT PLANS (pg 6)
Water Quality monitoring program
Water quality monitoring is going to be a big issue with our county. If our department has to take and test water samples it will be incredibly expensive and time consuming. The most streamline method for us to handle this issue will be to allow the home owner to take their own water samples. Unfortunately, this could lead to improper testing techniques and faulty samples.
This program will be very difficult to promote without a funding mechanism available or a program is figured in advance as part of the build-out of a sewer facility. If the RWQCB staff is intending to regulate this program away from sewer facilities it will make the process even harder. Septage management programs will require a lot of money and a reduction of environmental standards to allow the use of the by-product as fertilizer. If the by-product can not be used as fertilizer then land will have to be condemned for storage of the product. These storage facilities are never a friendly neighbor and are subject to numerous complaints. Without funding available no one will be willing to pursue such a project.
Program administration, staffing, records keeping etc.
This part of the program will be hard to accomplish immediately as all government agencies are having financial difficulties due to the economy and the State budget. San Luis Obispo County will need a minimum of four additional employees to follow-up on data, track records, issue inspection notices and complete inspections. (This is based on 20,000 systems or 5,000 systems per year. Each system will require one hour of data input, follow-up, and time to issue letters/reports. We will also need a technician to follow-up on mandatory repair inspections and spot check advanced treatment systems at a minimum of 2 hours per inspection).
2. Section VIII.D.2.a. Site Suitability (pg. 8 number 13, and number 21 on pg. 10)
This section limits buildings to one house per acre. This will limit the number of lots allowed to be built in rural areas and seems to remove the term “favorable conditions” for building on ½ acre lots. This regulation seems a bit stringent and not based on any specific data that docuements problem with groundwater in areas where ½ acre lots have been allowed.
3. VIII.D.2.e ONSITE SYSTEM MAINTENANCE (pg 11 number 4)
This regulation will require mandatory inspection and pumping every five years minimum. If county has 20,000 systems then we will have to issue 5,000 septic inspection / pumping letters a year. In order to keep up with the data, send out the notifications and follow-up, the county we will need additional employees. This is going to be difficult to fund with the current economy.
In summary if the proposed Basin Plan is approved as is, it will substantially increase the County’s operating costs and add to the cost of housing. Although it is very important to protect ground and surface waters of the State, it is equally important to provide reasonable regulations to maintain that end. This propsedBasin Plan asks for a substantial amount of protection yet does not offer any economic reward. It is important to balance protection with economic feasibility.
Section 13241 of the Porter Cologne Water Quality Control Act states:
Each regional board shall establish such water quality objectives in water quality control plans as in its judgment will ensure the reasonable protection of beneficial uses and the prevention of nuisance; however, it is recognized that it may be possible for the quality of the water to be changed to some degree without unreasonably affecting beneficial uses. Factors to be considered by a regional board in establishing water quality objectives shall include, but not be necessarily limited to, all of the following:
(d) Economic considerations.
(e) The need for developing housing within the region.
Thank you again for the opportunity to comment on the proposed draft.
Barry Tolle, REHS
County of San Luis Obispo Planning & Building Dept