The Sierra Club's Newsletter Checks In

The following comments appeared in the Sept newsletter on the Planning Commission recommendations on the Los Osos Sewer.


Santa Lucian • September 2009

Sewer Myths Busted

The County Planning Commission
hearings on the Los Osos Wastewater
Project shone a bright light on
various claims asserted by the County
and the Public Works Department
about the biggest, longest-running
public works project in county
history. They fell like autumn leaves
before the questioning of Commissioners
and in the face of hard data.
A short list, with corrections:
[in italics]

Gravity sewers don’t leak; any
evidence of such deficiency is a result
of old technology, the failure of 100-
year-old clay pipes, etc.

-- Major infiltration and inflow of
groundwater has been found in gravity
systems less than ten years old.

Gravity sewers are environmentally
preferable to STEP/STEG collection.

-- The only significant environmental
benefit of gravity over STEP is the
reduction of the amount of sludge
produced when a gravity system is
used with facultative ponds. If facultative
ponds are not used, there is no
environmental advantage to a gravity
sewer. Facultative ponds are not (yet)
part of the County’s project.

All collection systems would have
roughly equivalent impacts and the
Coastal Commission has no issues
with the selection of one over
another.

-- Dan Carl, Central Coast District
Manager, California Coastal Commission,
wrote to County Public Works
Director Paavo Ogren on July 15 to
say that sludge reduction should be
made a “a high priority in the
selection of preferred collection and
treatment technologies.”

The Tonini disposal site might not be
outside the water basin because, theoretically, there could be connecting
strata between the aquifers.

-- The Tonini site is outside the water
basin. Treated wastewater disposed of
at Tonini would be water wasted.

The Andre site cannot be used
because PG&E will not allow the hay/
grass crop that would be required to be grown under power lines.

-- PG&E restrictions apply to the
heights of trees and structures under
power lines, not grass and hay.

The use of recycled water in the Los
Osos basin cannot be required until
the basin has been adjudicated.

-- State law requires that recycled
water must be used in lieu of well
water by ag users if recycled water is
available.

“We’re trying to give the
county some guidance and
direction to avoid a train
wreck at the end of this
line.”
- Peter Douglas
Executive Director,
California Coastal Commission


A Sewer, Almost
Never did a project so flawed get so much better so fast

As a rule, improvements in what you
are given are extremely unlikely if you
simply take whatever is offered.
On August 13, after hundreds of
hours of study and public testimony,
two field trips, 8,000 pages of documentation
and 170 pages of findings
and conditions, the County Planning
Commission proved this point when it
approved the permit for the Los Osos
Wastewater Project.

The Commission vastly improved on
the project as originally submitted by
County Public Works -- a project that
had no chance of receiving a coastal
development permit due to its
impermissable environmental
impacts. Sewage will now be subjected
to a significantly higher level of
treatment, producing effluent that
can be safely recycled for use on
crops. The treatment plant and
disposal method will not consume
645 acres of prime agricultural land.
The treated effluent will remain in the
basin and be put to work curbing
saltwater intrusion instead of being
sprayed away outside the water basin
in the middle of a drought. A mandate
to reduce water use by 25 percent is
included, more than doubling the
originally proposed level of water
conservation.

The improved project demonstrates
the reason why the Sierra Club, in
agreeing at the outset that we all
needed to “support the project,”
elected not to follow the path of least
resistance in doing so. We joined with
concerned local citizens who insisted
that the project feature tertiary, not
just secondary treatment of wastewater;
that treated effluent be disposed
of inside, not outside, the ground
water basin and be made available to
growers to reduce pumping of the
lower aquifer and seawater intrusion;
and that a more aggressive water
conservation program be mandated.

And so it has come to pass.

Unfortunately, what the Commission
did not do, despite a wealth of
evidence that it should, was mandate
the use of a pressurized effluent
collection system and the use of
facultative ponds for treatment. The
selected gravity system and Biolac
treatment would result in greater
quantities of toxic sludge produced as
an end product of treatment. These
two parts of the project still need to
be changed to ensure that the County
takes the environmentally superior
course of action on the largest public
works project in its history.

The Environmental Impact Report
on which those decisions were based
was correctly and repeatedly characterized
by Commissioners as “flawed.”
They were being kind. Golden State
Water Co. correctly summed up the
fatal flaw of the EIR’s “failure to make
a connection between the facts
presented and the conclusions
reached.” Further: “because the
County fails to set forth an accurate
project description, a meaningful
alternatives analysis is impossible.
Because the DEIR does not provide a
stable project description to which
alternatives can be compared, the
‘alternatives’ presented in the DEIR
are more akin to a series of proposed
projects, rather than the means to
compare the worth and value of
alternatives to a proposed project.”

The Sierra Club is appealing the
certification of the EIR in order to
correct those flaws, correctly state the
project’s environmental impacts and
clarify the collection and disposal
options before a permit is approved.

The Planning Commission’s process
and the project that emerged from it
was a testament to the value of public
advocacy. Local residents, community
groups, wastewater experts and
environmental organizations brought
their concerns to the Commission,
backed them up with facts and data,
and the Commission listened.

Had we all heeded the call to “just
do it” and acquiesced to the project
that Public Works submitted to the
Planning Commission, none of the
above improvements would be part of
the project now.

When the permit comes before the
Board, for the sake of the aquifer, the
Morro Bay Estuary and the citizens of
Los Osos, those improvements need
to stay there, and two more need to
be added: an environmentally preferable
treatment method, and the
consideration of an alternative
collection system in the bidding
process.

"The estimated progress of seawater
intrusion since 2005 is the third, and
biggest bulge; the rate of progress
for the prior 20 years is shown in the
layers to the left of it. The rate of seawater
intrusion into the basin is now under the
Los Osos downtown and commercial area
and appears to be four to eitht times faster
than it was fourt years ago"

Cleath & Associates/Keith Weimer, LOSG