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EPA-9-CA-Santa Cruz-WWTP-7 9
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
215 Fremont Street
San Francisco, Ca. 94105
11 APR 1980
To all interested agencies, public groups, and concerned
individuals:
The Final Environmental Impact Statement (EIS) and
Environmental Impact Report (EIR) for the Santa Cruz
Areawide Wastewater Facilities Plan is being distri-
buted at this time for your review and comment. The Final
EIS/EIR has been prepared to conform with the requirements
of the National Environmental Policy Act of 1969 (NEPA) and
the California Environmental Quality Act of 1970 (CEQA),
as amended.
The Draft EIS/EIR was jointly issued by the Environ-
mental Protection Agency (EPA), Region IX and the City of
Santa Cruz on June 18, 1979. The Draft EIS/EIR was filed
with the State Clearinghouse (State Clearinghouse No.
79070310) and with the EPA Office of Environmental Review
(EIS Order No. 90599)f and circulated for review among
various federal, state, and local agencies as well as firms,
organizations, and concerned individuals.
Contained in this document are a record of the public
hearing, responses to the comments received at the public
hearing and in writing during the comment period. This
document, along with the Draft EIS/EIR, constitutes the Final
EIS/EIR.
The purpose of this project is to upgrade the existing
primary wastewater treatment plant (WWTP) to the level of
secondary treatment and to provide a new ocean outfall. The
project will not increase the existing WWTP capacity. . The
City of Santa Cruz intends to construct upgraded treatment
facilities and a new deep ocean outfall for the same capacity
as its existing facilities, i.e., 21 million gallons per
day, average dry weather flow.
The project alternative that has been selected is
Alternative ODj^. This alternative will provide secondary
treatment for the City of Santa Cruz and the Santa Cruz County
Sanitation District's wastewater at Nearys Lagoon with effluent
disposal through a new deep water ocean outfall.
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The Federal Water Pollution Control Act (Clean Water
Act) requires that secondary treatment be provided to waste-
waters prior to their discharge to the navigable waters of
the United States. However, the Clean Water Act also provides,
in certain circumstances, for temporary modification of the
secondary treatment requirement. The City of Santa Cruz
has applied for a modification of the secondary treatment
requirement. If granted, such modifications of the secondary
treatment requirement are temporary, and provide for only
a 5-year period. At the end of that period, monitoring data
will be evaluated to determine if a modification should be
renewed. If the city is granted this modification the selection
of the recommended project alternative probably would be
changed from Alternative 0D^A, secondary treatment at Nearys
Lagoon with discharge through a new deepwater ocean outfall,
to advanced primary treatment at Nearys Lagoon with discharge
through a new deep ocean outfall (Alternative OD7).
Written comments should be submitted within thirty (30)
days of the issuance of this Final EIS/EIR to:
U. S. Environmental Protection Agency
Region IX
Attn: Hearing Office (HE-141)
215 Fremont Street
San Francisco, California 94105
After review of those comments received on the Final
EIS/EIR, EPA will issue a public record of its decision on
the selected project alternative.
The Final EIS/EIR may be reviewed at the following locations:
U. S. Environmental Protection Agency
Region IX
Library
215 Fremont Street
San Francisco, California 94105
U. S. Environmental Protection Agency
Public Reference Unit (P.M. 213)
401 M Street, S.W., Room 2922
Washington, D.C. 20460
University of California
University Library
Santa Cruz, California 95060
Santa Cruz Public Library at the following locations:
Central Library
224 Church Street
Santa Cruz, California 95060
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Alba Branch Library
Alba Schoolhouse
Ben Lomond, California 95005
Aptos Branch Library
7 6 95 Soquel Drive
Aptos, California 95003
Ben Lomond Branch Library
9525 Mill Avenue
Ben Lomond, California 95005
Boulder Creek Branch Library
Central Avenue, next to Fi.rehouse
Boulder Creek, California 95006
Branciforte Branch Library
230 Gault Street
Santa Cruz, California 95062
Capitola Branch Library
411 Capitola Avenue
Capitola, California 95010
Felton Branch Library
6299 Gushee
Felton, California 95018
Freedom Branch Library
1941 Freedom Boulevard
Freedom, California 95076
Garfield Park Branch Library
705 Woordrow Avenue
Santa Cruz, California 95060
LaSelva Beach Branch Library
314 Estrella Avenue
LaSelva Beach, California 95076
Scotts Valley Branch Library
3050 Porter
Soquel, California 95073
Watsonville Public Library
310 Union
Watsonville, California 95076
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Please bring this notice to the attention of all persons
who would be interested in this matter.
Sincerely yours,
I y£>aul De Falco, Jr.
V/ Regional Administrator
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SANTA CRUZ FINAL ENVIRONMENTAL IMPACT STATEMENT
Distribution List
The following distribution list was compiled from
an EPA list of required federal and state recipients and
incorporated additional addresses supplied by representa-
tives of the City of Santa Cruz and the Santa Cruz County
Sanitation District. Individuals who attended the public
workshops and have requested copies have been included
on this list.
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FEDERAL AGENCIES
U. S. Envirormental Protection Agency
Office of Legislation A-103
Congressional Affairs Division
Washington, DC 20460 (4 copies)
U. S. Envirormental Protection Agency
Office of Public Affairs A-107
Washington, D C 20460 (2 copies)
U. S. Envirormental Protection Agency
Office of Water Programs Operations
Oil arri Special Materials Control
Division (WH-548) J
Washington, DC 20460 (2 copies)
U. S. Envirormental Protection Agency
Office of Federal Activities A-104
(Attn: Kathi Wilson)
Washington, DC 20460 (10 copies)
U. S. Envirormental Protection Agency
Office of External Relations
Region IX, EPA Library
215 Fremont Street
San Francisco, CA 94105 (2 copies)
U. S. Envirormental Protection Agency
Public Reference Unit (PM213)
Room 2922
401 "M" Street, SW
Washington, DC 20460 (2 copies)
U. S. Envirormental Protection Agency
Region IX
Attn: Bill Helphingstine
215 Franont Street
San Francisco, CA 94105 (2 copies)
U. S. Envirormental Protection Agency
Region IX
Attn: Mr. Chuck Flippo
Public Information Center
215 Fratont Street
San Francisco, CA 94105 (20 copies)
Assistant Secretary-Program Development
and Budget
Attn: Office of Envirormental Project
Review
Department of Interior Pm 5311
Washington, DC 20240 (20 copies)
Council on Envirormental Quality
722 Jackson Place, N.W.
Washington, DC 20006 (5 copies)
Department of Health, Education,
and Welfare
Region IX
50 Fulton Street
San Francisco, CA 94102 (2 copies)
Department of Housing and Urban Develop-
ment
San Francisco Area Office
One Bnbarcadero Center, Suite 1600
San Francisco, CA 94111
Attn: Mr. Lawsan (2 copies)
Corps of Engineers
South Pacific Division
630 Sansome Street
San Francisco, CA 94111 (2 copies)
U. S. Army Corps of Engineers
San Francisco District
Envirormental Branch
211 Main Street
San Francisco, CA 94105 (2 copies)
U. S. Army Corps of Engineers
San Francisco District
211 Main Street
San Francisco, CA 94102
Attn: Mr. Harry Erlich
U. S. Army Corps of Engineers
Executive Director of Civil Wbrks
Office of the Chief of Engineers
Washington, DC 20314 (2 copies)
U. S. Department of the Interior
Western Division
P. 0. Box 36033
San Francisco, CA 94102
U. S. Department of the Interior
Bureau of Outdoor Recreation
Rocm 5102, Federal Building
450 Golden Gate Avenue
San Francisco, CA 94102
U. S. Fish and Wildlife Service
Attn: Mr. Fred Nakagi
2800 Cottage Way
Sacramento, CA 95825
U. S. Department of the Interior
Bureau of Reclamation
Attn: Haydn C. Lee, Jr.
2800 Cottage Way
Sacramento, CA 95825
Federal Highway Administration
Two Embarcadero Center
Rocm 530
San Francisco, CA 94111
Urban Mass Transportation Administration
Region IX Box 36125
450 Golden Gate Avenue
San Francisco, CA 94012
Departrrent of Transportation
12th Coast Guard District
630 Sanscme Street
San Francisco, CA 94126
U. S. Geological Survey
845 Middlefield Rd.
Menlo Park, CA 94025
U. S. Dept. of Health, Education and
Welfare
Region IX
50 Fulton Street
San Francisco, CA 94102
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Ccnm. of Hater Quality
AttmSMses Larocca
1111 - 18tfr«treet, N. W.
P. 0. Box 19266^v_
Washington, DC 2002^
Federal Energy Mministration
Attn: Envirormental Snpacts Division
New P. O. Building
12th and Pennsylvania Ave., N.H.
Washington, DC
V. S. Food and Drug Mnimstration
Attn: David Alton,
Regional Shellfish Consultant
50 Fulton Street
San Francisco, CA 94118
Advisory Council
on Historic Preservation
P. 0. Boot 25085
Denver, 00 80225
Mr. Bill Leet
National Marine Fisheries Service
3150 Paradise Drive
Tiburon, CA 94920
Department of Oatxnerce
Dr. Itobert Kifer
3300 Hhitehaven Street, N.W.
Washington, DC 20235
National Oceanic and
Atmospheric flckninistration^
National Marine Fisheries Service
Tishnan Building
525 Market Street
San Francisco, CA 94105
Dr. William Aron, Director
Office of Ecology and
Environmental Conservation
Boon 5813
Department of Oonmerce
Washington, DC 20230
Mr. Ben Mierement
Office of Coastal Zone Managsnent
National Oceanic and
Atmospheric Administration
3300 Whitehaven Street, N.W.
Washington, DC 20235
Regional Leader, Western Region
Water Resources Council
Room 806
2120 "L" Street, N.W.
Washington, DC '20037
State Conservationist
Soil Conservation Service
U. S. Department of Agriculture
P. O. Bok 1019
Davis, CA 95616
SwiFrancisco Field Representative
NatloftekLOcean Survey
Federal BuH&im, Box 36114
450 Golden GateAvcQue
San Francisco, CA 94X03.
Deputy Assistant Secretary for
Envirormental Affairs
Attn: Dr. Sidney Galler
Department of Comnerce
Oonmerce Building, Roan 2816
Washington, DC 20230 (2 copies)
Department of Transportation
450 Golden Gate Avenue
San Francisco, CA 94102 (2 copies)
Department of Ccnmerce
National Marine Fisheries Service
Southwest Region
300 South Ferry
Terminal Island, CA 90731 (2 copies)
Department of
Office of Oceanographer of the Navy
The Madison Building
732 N. Washington Street
Alexandria, VA 22314 (2 copies)
Department of Agriculture
Soil Cc3ns$rvation Service
318 Union ""-- .,
Watsonville, CA^95J)76
U. S. Department of Agriculture
Agricultural Extension Service
Attn: Mr. Robert Ayers
University of California
Berkeley, CA 94705
U. S. Department of Agriculture
Office of the Secretary
Envirormental Oiality Activities
Roan 307A
14th and Independence Avenue, S.W.
Washington, DC 20250 (2 copies)
U. S. Department of Agriculture
Soil Conservation Service
P. 0. Box 1019
Davis, CA 95616
Mvisory Council on Historical
Preservation
1522 "K" Street
Washington, DC 20005 (2 copies)
STATE AGENCIES
Office of Planning and Research
Attn: Mr. William G. Kirkham
State Clearinghouse
1400 - 10th Street
Sacramento, CA 95814 (20 copies)
Department of Water Resources
1416 Ninth Street
Sacramento, CA 95814
Mr. Neil Dunham, Chief
Division of Water Cuality
State Water Resources Control Board
P. 0. Box 100
Sacramento, CA 95801
Air Resources Board
1709 - 11th,Street
Sacramento, CA 95814
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Resources Agency
Room 1311
1416 Ninth Street
Sacramento, CA 95814
Department of Fish and Game
State Headquarters
1416 Ninth Street
Sacramento, CA 95814
Department of Public Health
W&ter Sanitation Division
Attn: Morgan Stewart
2151 Berkeley Way
Berkeley, CA 94704
California Department of
Navigation and Ocean Development
1316 Ninth Street, Rocra 1336
Sacramento, CA 95814
Regional Water Quality Control Board
Central Coast Region
1122-A Laurel Lane
San Luis Obispo, CA 93401
Mr. Russel W. Porter, Chief
Grants and Statewide Studies Division
Department of Parks and Recreation
P. O. Box 2390
Sacramento, CA 95811
Manterey Bay Unified
Air Pollution Control District
1270 Natividad Road
Roan 105
Salinas, CA 93906
California Coastal Zone Conservation
Conmission
631 Howard Street
San Francisco, CA 94105
Ms. Susan Hansch
Central Coast Regional Coastal Zone
Conservation Ccrrmission
701 Ocean Street, Roan 300
Santa Cruz, CA 95060 (20 copies)
Dr. Mike Martin
California Department of Fish and Game
2201 Garden Road
Monterey, CA 93940
Mr. Michael L. Johnson
California Department of Fish and Game
2201 Garden Road
Monterey, CA 93940
Agricultural Advisors
University of California
Farm & Hcroe Advisors
1432 Freedom Boulevard
Watsonville, CA 95076
State Office of Historic Preservation
1416 - 9th Street
Sacramento, CA 95814
California Department of Parks and
Recreation
Grants and Statewide Studies Division
Attn: Mr. Russel W. Porter, Chief
P. 0. Bex 2390
Sacramento, CA 95811
COUNTY AGENCIES
Central Santa Cruz County
Water District
400 Cck Road
Aptos, CA 95003
Department of Environmental Health
Attn: Mr. Hon Johanson,
Watershed Manager
701 Ocean Street
Santa Cruz, CA 95060
Department of Environmental Health
Attn: Mr. Ray Talley
701 Ocean Street
Santa Cruz, CA 95060
Department of Health
Santa Cruz County
Attn: Dr. R. H. Svihus
1060 Eneline Street
Santa Cruz, CA 95060
Department of Parks and Recreation
Fish and Game Conmission
County of Santa Cruz
701 Ocean Street
Santa Cruz, CA 95060
Department of Public Works
County of Santa Cruz
Attn: Mr. Don Porath, Director
701 Ocean Street
Santa Cruz, CA 95060
Department of Public Works
County of Santa Cruz
Attn: Mr. Dennis Daughters
701 Ocean Street
Santa Cruz, CA 95060
Department of Planning
County of Santa Cruz
Attn: Tan Burns
701 Ocean Street
Santa Cruz, CA 95060
Department of Planning
County of Santa Cruz
Attn: Mr. Myron Jaooles
701 Ocean Street
Santa Cruz, CA 95060
Monterey Bay Unified
Air Pollution Control District
1270 Natividad Road
Room 105
Salinas, CA 93906
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Parks, Open Space and
Cultured Services Ocrmission
701 Ocean Street
Santa Cruz, CA 95060
Santa Cruz County Housing
Authority
Attn: Mr. Rod Rulley
1543- 1/2 Pacific Avenue
Santa Cruz, CA 95060
Supervisor Dan Ferbus
Board of Supervisors
County of Santa Cruz
701 Ocean Street
Santa Cruz, CA 95060
Supervises: Pat Liberty
Board of Supervisors
County of Santa Cruz
701 Ocean Street
Santa Cruz, CA 95060
Supervisor Marilyn D. Liddiceat
Board of Supervisors
County of Santa Cruz
701 Ocean Street
Santa Cruz, CA 95060
Supervisor Chris Matthews
Board of Supervisors
County of Santa Cruz
701 Ocean Street
Santa Cruz, CA 95060
Supervisor Gary Patten
Board of Supervisors
County of Santa Cruz
701 Ocean Street
Santa Cruz, CA 95060
Hater Advisory Conmission
County of Santa Cruz
Attn: Mr. Morris Allen, Chairman
701 Ocean Street
Santa Cruz, CA 95060
Water Projects
County of Santa Cruz
Attn: E. R. Hanna
701 Ocean Street
Santa Cruz, CA 95060
Mr. Gerald Bowden
Santa Cruz City Planning
Cannission
225 Ross Street
Santa Cruz, CA 95060
REGIONAL GCVEFTWEOT
Association of Monterey
Bay Area Goverrwents
798 Cass Street
Monterey, CA 93940
LOCAL AGENCIES
A^tiqrftural Cairoissioner
Santa C?T»^Qff ice
1100 Bneline^StJCMt
Santa Cruz, CA 95060.
Morris Allen
Box 682
Santa Cruz, CA
95061
Mr. Morris Allen
City of Santa Cruz Vfeter
Department
809 Center Street
Santa Cruz, CA 95060
Aptos Chanter of Ccumerce
9 Rancho Del Mar Shopping Center
Aptos, CA 95003
Mr. Robert Bell
Joint Santa Cruz City-County
Lighthouse Field
1424 W. Cliff Drive
Santa Cruz, 'CA 95060
City Manager
City Hall
250 Main Street
Watsonville,CA 95076
City Manager
City of Capitola
Capitola City Hall
420 Capitola Avenue
Capitola, CA 95010
City Manager
City of Santa Cruz
City Hall
809 Center Street
Santa Cruz, CA 95060
City Manager
Scotrts Valley City Offices
370 Mt. Hermon Road
Scotts Valley, CA 95066
Chamber of Commerce
P. 0. Box 921
Santa Cruz, CA 95061
Chamber of Ccumerce of
Greater Capitola
115 Capitola Avenue
Capitola, CA 95010
Ccnnunity Action Board
P. O. Booc 1380
Santa Cruz, CA 95060
Mr. John Oooper
Director of Public Works
City Hall
250 Main Street
Watsonville, CA 95076
Capitola City Council
420 Capitqla Avenue
Capitola, CA 95010
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Mr. John Crivello
Director of Public Works
City of Scotts Valley
City Hall
370 Ht. Hermon Road
Scotts Valley, CA 95066
Mr. Ron Crooks,
Chairman of the Board
La Selva Beach Park & Recreation
District
106 Playa Boulevard
La Selva Beach, CA 95076
Ms. Carole De Palma
City Councilwcman
City Hall
809 Center Street
Santa Cruz, CA 95060
Mr. Robert DeKitt
Zoning Board
217 Pacheco
Santa Cruz, CA 95060
Mr. Tarry Edler
City nouncilman
City Hall
809 Center Street
Santa Cruz, CA 95060
Mr. Harris Farris
Reclamation District 2049
318 - 1/2 Main Street
Vfataonville, CA 95076
Mr. Wilson H. Fieberling
Director of Public Hbrks
City of Santa Cruz
809 Center Street
Santa Cruz, CA 95060
Mr. Scott Galloway, Manager
Santa Cruz Transit District
City of Santa Cruz
809 Center Street
Santa Cruz, CA 95060
Mr. Joe Ghio
City Councilman
City Hall
809 Center Street
Santa Cruz, CA 95060
Mr. Bob Johnson
Soquel Creek Hater District
5180 Soguel Drive
Soquel, CA 95073
Mr. Peter Katlberger, Director
Santa Cruz City Planning Dept.
809 Center Street
Santa Cruz, CA 95060
Janes B. Leask, Chairman
Santa Cruz Port Ccnmission
135 Fifth Avenue
Santa Cruz, CA 95060
Mr. John Mahaney
City Oouncitaan
City Hall
809 Center Street
Santa Cruz, CA 95060
Mr. Spiro Mellis
City Councilman
City Hall
809 Center Street
Santa Cruz, CA 95060
Ms. Charlotte Melville
City OounLilw»m«M*
City Hall
io\o Western vr.iv/e
Santa Cruz, CA 95060
Mr. Burt Muhly
City Oouncilman
City Hall
809 Center Street
Santa Cruz, CA 95060
Mr. Charles Palmtag
City Councilman
City of Watsonville
P. 0. Box 430
Watsonville, CA, 95076
Parks & Recreation Department
701 Ocean Street
Santa Cruz, CA 95060
L. M. Peterson, Port Director
Santa Cruz Port District Ccnmission
135 Fifth Avenue
Santa Cruz, CA 95060
Public Affairs, Carmunity Planning
University of California
Santa Cruz
Santa Cruz, CA 95060
Mr. Steve Russell
City of Santa Cruz Planning Dept.
809 Center Street
Santa Cruz, CA 95060
Scotts Valley City Council
370 Mount Hermon Road
Scotts Valley, CA 95060
Ms. Marsha Shanle
General Plan Ccnmittee
504 California Street
Santa Cruz, CA 95060
Mr. Tfcm Shanle
Housing Advisory Ccnmittee
P. 0. Box 1119
Santa Cruz, CA 95060
Mr. Raynor Talley
Environmental Health Department
County of Santa Cruz
701 Ocean Street
Santa Cruz, CA 95060
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Mr. Kenneth B. Webb, President
Redwood Resource Conservation District
5381 Old San Jose Road
Santa Cruz, CA 95060
Mr. Lather White
Special Services Districts Engineer
P. O. Box 419
Salinas, CA 93901
Mrs. Betty Young, Clerk of the Board
Opal Cliffs Park & Recreation District
4200 Oped. Cliffs Drive
Santa Cruz, CA 95062
GROUPS
The Adam E. Treganza
Anthropology Museum
San Francisco State University
1600 Balloway Avenue
San Francisco, CA 94132
Audubon Society
Attn: Mrs. Winifred Green
2656 Partola Drive
Santa Cruz, CA 95062
Beach Area Neighborhood
Association
Attn: Mrs. June Sievertson
512 Second Street
Santa Cruz, CA 95060
Beach Area Property Owners
Attn: Mr. Ed Tunnison
124 First Street
Santa Cruz, CA 95060
California Canners and Growers
312 Stockton Avenue
San Jose, CA 95126
California Institute
of Man in Nature
P. O. Box 392
Berkeley, CA 94701
California Native Plant Society
2490 Charming Way, Rocm 317
Berkeley, CA 94704
California Ttmorrow
Mcxiadnock Building
681 Market Street
San Francisco, CA 94105
California Vfeterfowl Association
Attn: Dr. James Tanous
1187 University Drive
Menlo Park, CA 94025
California Wildlife Federation
Attn: Executive Director
P. 0. Box 9504
Sacramento, CA 95826
Citizens Ccnmittee on Camtunity
Inpravement
Attn: Mr. Robert Darrow
Suite 6, Pacific & Lincoln
Santa Cruz, CA 95060
Canraunity Action Board
1100 Bneline Avenue
Santa Cruz, California
Canraunity Council of North
Santa Cruz County
P. 0. Box 1228
Santa Cruz, CA 95060
Convention and Visitors' Bureau
Church and Center Streets
Santa Cruz, CA 95060
Downtown Association of
Santa Cruz
1367 Pacific Avenue
Santa Cruz, CA 95060
Downtown Businessnen1 s Association
1205 Pacific
Santa Cruz, CA 95060
Downtown Chamber of Commerce
Mr. Ron Miller, the Haberdashery
110 Cooper Street
Santa Cruz, CA 95060
Dcwntown Neighborhood Association
Attn: Ms. Cynthia Mathewes
316 Walnut Street
Santa Cruz, CA 95060
East of Branciforte Neighborhood
Association
Attn: Mr. Jim Franks
417 Trevathan
Santa Cruz, CA 95060
Ecology Action of Santa Cruz
Attn: Mr. Burl Mass
1260-17th Avenue
Santa Cruz, CA 95060
Ecology Center
13 Columbus Avenue
San Francisco, CA 94111
Environmental Defense Fund
2728Ourant Avenue
Berkeley, CA 94704
Fredick Street Neighborhood
Association
Attn: Ms. Shelley Hatch
228 Owen
Santa Cruz, CA 95060
Friends of the Earth
529 Canmercial Street
San Francisoo, CA 94111
Friends of the Earth
124 Spear Street
San Francisco, CA 94105
Friends of the River Downtown
105-7 Post Street
Santa Cruz, CA 95060
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Historic Preservation Oaimission
Attn: Ms. Virginia Sharp
509 Meder Street
Santa Cruz, CA 95060
Homeowners Association - Shelter
Lagoon
104 Shelter Lagoon Drive
Santa Cruz, CA 95060
Hopkins Marine Station
Stanford University
Cabrillo Point
Pacific Grove, CA 93950
Golf Course Oorrmittee
Attn: Mr. Al Tosta
230 Majors
Santa Cruz, CA 95060
King Street Neighborhood Association
Attn: Mr. John Dizikes
1622 King Street
Santa Cruz, CA 95060
Kiwanis Club
Attn: Mr. Jack Ghielmetti
617 Park Way
Santa Cruz, CA 95060
la Selva Beach Improvement
Association
Cannunity Clubhouse
Attn: Mrs. Barbara Rasooe
314 Estrella Avenue
La Selva Beach
Watsanville, CA 95076
League of Wbmen Voters
Attn: Mrs. Edna Hecht
424 Simns Road
Santa Cruz, CA 95060
League of tfcmen Voters
c/o Mrs. Bess Luker
4602 Old San Jose Road
Santa Cruz, CA 95073
Lighthouse Point Neighborhood
Association
Attn: Ms. Millie Carlson
209 Lighthouse Avenue
Santa Cruz, CA 95060
Lions Club
Attn: Mr. Doug Thome
2315 Vine Hall Road
Santa Cruz, CA 95060
Lockheed Missiles & Space Company
Attn: M. L. Sellers
P. 0. Box 504
Sunnyvale, CA 94088
Mission Escalona Neighborhood
Delegation
Attn: Mr. Harold Steen
114 Escalora
Santa Cruz, CA 95060
NAACP
Attn: Mr. Jinny Griffin
P. O. Bok 1433
Santa Cruz, CA 95060
ratsual Resources Defense Council
Attn: Mts^Peter Sly
664 Hamilta?t\_
Palo Alto, CA 943QJ.
Ocean View Neighborhood
Association
Attn: Mr. Alan Holbert
208 Ocean View Avenue
Santa Cruz, CA 95060
Off-Street Parking CCrmission
Attn: Mr. Robert Fuller
161 Archer Drive
Santa Cruz, CA 95060
Operation Wilder
P. O. Box 2266
Santa Cruz, CA 95060
Optimists Club
Attn: Mr. Spencer Ward
403 Nobel Drive
Santa Cruz, CA 95060
Parks & Recreation Cantnission
Attn: Mr. Don McNeal
133 Segri Place
Santa Cruz, CA 95060
Port District COimission
Attn: Mr. Norman Lezin
135 Fifth Avenue
Santa Cruz, CA 95060
Prospect Heights Neighborhood
Association
Attn: Ms. Judy Primavera
405 Prospect Heights
Santa Cruz, CA 95060
Redevelopment Ccmnission
Attn: Mr. Allan Levin
209 Vista Bella Drive
Santa CruZj CA 95060
Rio Del Mar Improvement
Association
Attn: Mr. Clayton Ward
115 Doverood Lane
Rio Del Mar, CA 95003
Rio Del Mar Improvement Association
c/o Mr. Craig Ellis
190 Greenbriar Drive
Rio Del Mar, CA 95003
Rio Del Mar Improvement Association
Rio Del Mar News
Attn: Mrs. Carlyle Miller
520 Alta Drive
Aptos, CA 95003
Rotary Club
Attn: Mr. Eugene Flailing
548 Ocean Street
Santa Cruz, CA 95060
Santa Cruz Angling and Hunting Club
401 Pennsylvania Avenue
Santa Cruz, CA 95060
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Santa Cruz Angling and Hunting Club
Attn: Mr. Boy T. Williamson
1440 El Dorado Avenue
Santa Cruz, CA 95060
Santa Cruz Area Chamber of Caimerce
P. 0. Box 921
Santa Cruz, CA 95060
Santa Cruz Bird club
Attn: Mr. David Bookman
531 Sunner Street
Santa Cruz, CA 95060
Santa Cruz Board of Realtors
1525 Seabright Avenue
Santa Cruz, CA 95060
Santa Cruz City Water Ccmnissicn
Attn: Mr. Auther Backwood
130 RixJolphson
Santa Cruz, CA 95060
Santa Cruz County Parents Assn.
Attn: Mr. John Brissenden
4421 Soquel Drive
Soquel, CA 95073
Santa Cruz County Taxpayers
P. O. Boot 1493
Santa Cruz, CA 95060
Santa Cruz Historical Society
P. O. Boot 246
Santa Cruz, CA 95061
Santa Cruz Jaycees
1222 Pacific Avenue
Santa Cruz, CA 95060
Santa Cruz Organization foe Progress
and Euthenics (SCOPE)
Mr. Ian McPhail, Chairman
1522 Pacific Avenue
Santa Cruz, CA
SCOPE
250 Ihunderbird Drive
Aptos, CA 95003
and Gun Club
le
Santa Cruz, CA
Save Lighthouse Point
Mr. Steven Carlson
209 Lighthouse Avenue
Santa Cruz, CA
Save the San Lorenzo River Assn.
Attn: Ms. Mary Harmer
P. O. Boot 118
Felton, CA 95060
Project SCOOT
1126 Soquel Avenue
Santa Cruz, CA 95060
Seacliff Impaxvanent Association
P. O. Bcoc 533
Aptos, CA 95003
Senior Center
222 Market Street
Santa Cruz, CSV 95060
Sierra Club
Ventana Chapter
Conservation Chairman
1257 Joselyn Canyon Road
Monterey, CA 93940
Sierra Club
Santa Cruz Regional Group
219 Walnut Avenue
Santa Cruz, CA 95060
Thrust Four
2724 Vfesatch Drive
Mountain View, CA 94040
University Terrace Hcraeowners
Attn: Mr. Bob Settle
227 Segre Place
Santa Cruz, CA 95060
Watsonville Chamber of Cartnerce
444 Main Street
Watsonville, CA 95076
Western Limits Association
Attn: Mr. Jon Wittwer
1122 Western Drive
Santa Cruz, CA 95060
Westlake Hcmeowr.ers Association
Attn: Mr. Bob Maddock
323 Majors Street
Santa Cruz, CA 95060
West of Branciforte Neighborhood
Association
Attn: Mr. Mitchel Page
148 Pryce Street
Santa Cruz, CA 95060
William James Association
108 locust Street
Santa Cruz, CA 95060
INDIVIDUALS
Mr. John M. Doane
3511 Floral Drive
Santa Cruz, CA 95060
K&i-^gne Garni
523 CenEer--Street
Santa Cruz, CA~95©6Q.
^fT-aoJMrs. R. D. Sharp
509 Meder""Steeet:
Santa Cruz, CA~9566Q
Mrs. Barbara White
1211 Webster Street
Santa Cruz, CA 95060
Mr. Earl Harris
144 Peyton Street
Santa Cruz, CA 95060
Mr. William Neubauer
c/o Santa Cruz Sentinel
207 Church Street
Santa Cruz, CA 95060
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Mr. Claude Bernasconi
Hiimann Laboratories, UCSC
Santa Cruz, CA 95060
University of California
Attn: Mr. Gary Griggs
Santa Cruz, CA 95060
Mr. Robert Byington
221 Berkeley May
Santa Cruz, CA 95062
Mrs. Glenn Specht
3070 Ledyard Way
Aptos, CA 95003
tttvJJon Kassler
3361 Pcile^venue
Aptos, C3V 93803^
Mr. Peter Scott
1520 Escalona Drive
Santa Cruz, CA 95060
L. Cleveland
203 Elva-Ocive
Aptos, CA 95803^
Mr. Dennis Burns
1818 Graham Hill Road
Santa Cruz, OV 95060
Mr. Carl Tattle
4425 Clares Street
Capitola, CA- 95060
Gary and Connie Sahl
825 Seacliff
Aptos, CA 95003
James and Barbara Reding
P. O. Box 755
Capitola, CA 95010
Mrs. Ruby Strong
4340 Scotts Valley Drive
Sootts Valley, CA 95066
L. R. Teller
Mid County Realty
921 Old San Jose Road
Soquel, CA 95303
EBtwaeSwanson
111 NevTtonfcggmery Street
San Francisco /~t7S>-S410 5
Mr. Robert Edwards
Archeology Department
Cabrillo College
6500 Soquel Drive
Aptos, CA 95003
Mr. Norman Lezin
Salz Leathers, Inc.
P. 0. Box 1120
Santa Cruz, CA 95061
Mr. Hal Bissell
Jones & Stokes Associates, Inc.
2321 P Street
Sacramento, CA 95816
Mr. Charlie long
Bartie Wells Associates
100 Bush Street
San Francisco, CA 94104
Dr. Pat Kinney
Kinnetic laboratories, Inc.
1820 West Cliff Drive
Santa Cruz, CA 95060
Mr. Jim Lee
State Water Resources Control Board
P. 0. Box 100
Sacramento, CA 95801
Mr. Bill Campbell
State Water Resources Control Board
P. 0. Box 100
Sacramento, CA 95801
Mst*-€t)£istine Kahn
Watsonvilie^City Hall
P. 0. Box 43(5^^^^
Watsonville, CA 95VH,
Mr. Dan DeGrassi
4173 La Madrona Drive
Santa Cruz, CA 95060
Stagnaro Cottardo Fishing Corp.
Center of Municipal Warf
Santa Cruz, CA 95060
Mr. Jercme S. Nelson
Harding Lawson & Associates
P. 0. Box 3030
San Rafael, CA 94902
Ms. Roberta Mundie
Gruen Gruen & Associates
564 Howard Street
San Francisco, CA 94105
Mr. Carl Harris
Harris & Associates
3708 Mt. Diablo Boulevard
Lafayette, CA 94549
James M. Montgomery,
Consulting Engineers, Inc.
1990 N. California Boulevard,
Suite 444
Walnut Creek, CA 95696
Mr. Cleve Anderson
219 Chioo Avenue
Santa Cruz , CA 95060
Mr. Richard Pierce
University of California,
Santa Cruz
Santa Cruz, CA 95060
Dr. Robert Swenson
Cabrillo Ccnmunity College
6500 Soquel Drive
Aptos, CA 95062
Mr. Bill Doyle
Biology Ihimann Laboratory
University of California,
Santa Cruz
Santa Cruz, CA 95064
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Ms¦ Pat"
Envirormental Protection Agency,
Region IX
215 Frenont Street
San Francisco, CA 94105
Mr. John Goni
California Regional water
Quality Control Board
Central Coast Region
1122-A Laurel Lane
San Luis Obispo, CA 93401
Jfc>4jQbert Graham
572 Safitevftlargarita
Aptos, CA 55004.
Jeriks and Marnson
543 Byron Street
Palo Alto, CA 94301
Mr. Greg Rainbolt
250 San Jose Street
Santa Cruz, CA 95060
Mr. Chuck Allen, Project Coordinator
Watsonville Food Processors Energy
and Water Conservation Association
c/o Key Realty
2734 Freedom Boulevard
Watsonville, CA 95076
Pacific Gas and Electric Coqpany
1543 Pacific Avenue
Santa Cruz, CA 95060
Pacific Telephone
212 Locust
Santa Cruz, CA 95060
Mr. Robert L. Mills
Associate Project Manager
Brown and Caldwell,
Consulting Engineers
1501 North Broadway
Walnut Creek, CA 94596
Dr. Denny Parker,- Vice President
Brown & Caldwell,
Consulting Engineers
1501 North Broadway
Walnut Creek, CA 94596
John Inglis Frozen Foods Co.
125 Chestnut
Santa Cruz, CA 95060
Green Giant Company
735 W. Beach
Watsonville, CA 95076
Thomas J. Lipton, Inc.
2200 Deleware Avenue
Santa Cruz, CA 95060
William Wrigley, Jr. Co.
2801 Mission
Santa Cruz, CA 95060
Pacific Coast Producers
104 Bronson
Santa Cruz, CA 95060
Santa Cruz Wire and Manufacturing Co.
411 Swift
Santa Cruz, CA 95060
MEDIA
^Tle^totos Voice
P. oTbok^747
Aptos, CA 950Q3
Attn: Ms. May Bartett
Calerillo Times & Green Sheet
Attn: Mr. Bob Smith
4895-A Capitola Road
Capitola, CA 95010
Central California Ccmnunication
Corporation
708C Capitola Avenue
Capitola, CA 95010
County News
Attn: Ms. Kaxine Cohen
P. O. Box 327
Aptos, CA 95003
KSBW - IV Channel 8 NBC
311 Soquel Avenue
Santa Cruz, CA 95060
KSCO
Attn: Mr. Dick Little
2300 Portola Drive
Santa Cruz, CA 95060
Reg ister-Pajaronian
1000 Main Street
Watsonville, CA 95076
Santa Cruz Independent
1383 Pacific Avenue
Santa Cruz, CA 95060
Santa Cruz Sentinel
Attn: Mr. Tan Hoenig
207 Church Street
Santa Cruz, CA 95060
Peoples Press
204 Church Street
Santa Cruz, CA 95060
Santa Cruz Mobile News
2735 Portor
Soquel, CA 95073
Scotts Valley News
4740 Scotts Valley Dr.
Scotts Valley, CA 95073
Scotts Valley Banner
4859 Scotts Valley Dr.
Scotts Valley, CA 95073
Valley Press
5901 Highway 9
Felton, CA
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LIBRARY
University of California
University Library
Attn: Mr. S. Weinrich
Santa Cruz, CA 95060
Santa Cruz Public Library
Attn: Mr. Atkins
224 Church Street
Santa Cruz, CA 95060 (14 copies)
Watsonville Public Library
310 Union
Watsonville, CA 95076
Cabrillo Cemrnunity College
College Library
6500 Soquel Drive
Aptos, CA 95303
LEGISLATORS
Honorable S. I. Hayakawa
United States Senator
452 Senate Office Bldg.
Washington, DC 20510
Ifonorable Alan Cranston
United States Senator
452 Senate Office Bldg.
W&shirajton, DC 20510
Honorable Leon E. Panetta
United States Congressman
201 Ocean Street
County Bldg., 5th floor
Santa Cruz, CA 95060
Assemblyman Henry J. Mello
201 Ocean Street
County Bldg., 5th Floor
Santa Cruz, CA 95060
Honorable Robert Ninrro
State Senator
701 Ocean Street
County Bldg., 5th Floor
Santa Cruz, CA 95060
Assemblywcman Carol Hallett
32 E. Alisal, Roam 201
Salinas, CA 93901
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ADDITIONS TO THE DISTRIBUTION LIST SINCE THE ISSUANCE OF THE DRAFT EIS/EIR
MR. DAVE BOCKMAN
SIERRA CLUB
P.O. BOX 604
SANTA CRUZ, CA 95061
MR. HERB MARICIE
CALIF. STATE LANDS COMMISSION
1807 - 13TH STREET
SACRAMENTO, CA 95825
ALICE M. OST, LIBRARIAN
DAMES AND MDORE
SUITE 1000
1100 GLENDON AVENUE
LOS ANGELES, CA 90024
MS. TERRY WALTER
DEPT. OF PUBLIC WORKS
SANTA CRUZ, CA
DEPT. OF HJBLIC WORKS
809 CENTER STREET
SANTA CRUZ, CA 95060
ATTN: CAROL GIIWIS0N (3 copies)
MR. FRED SCHMIDT, DOCUMENTS
LIBRARIAN
COLORADO STATE UNIVERSITY
FORT COLLINS, GO 80523
S. ALEX ANDERSON
GREEN PEACE
125 BERCH STREET, #44
SANTA CRUZ, CA 95060
MS. JANE McDONOUPH
323 CHURCH STREET
SANTA CRUZ, CA 95060
MR. BILL HELPHIRGSTINE
1355 LINCOLN LAKE, N.E.
LOWELL, MI 49331
MR. JOE DOWHAN
U.S. FISH & WILDLIFE SERVICE
2800 COTTAGE WAY
SACRAMENTO, CA 95825
MS. JANIE FIGEN, CHAIRMAN
SIERRA CLUB, VENTANA CHAPTER
1443 DEER FLAT ROAD
MONTEREY, CA 93940
DR. GEORGE KAZYNSKI
DAVY-McKEE CD.
2700 COMPASS DRIVE
SAN MATEO, CA 94403
MR. RANDALL O. RICE
340 - 6TH AVENUE
SANTA CRUZ, CA 95062
MR. DAVID RESNICK-SANNES
10061 RIVERSIDE DRIVE
BEN IOMOND, CA 95005
MR. THOMAS L. BOLICH, SANITATION
ENGINEER
701 OCEAN STREET
SANTA CRUZ, CA 95060
MR. JERRY BOSCH
GREENBELT COMMITTEE
401 PAimCIES
SANTA CRUZ, CA 95062
MS. JULIA PATTERSON
CELEN, MARRIN, JOHNSON & BRIDGES
SUITE 2200
NUMBER 2 ENBARCAEEFO CENTER
SAN FRANCISCO, CA 94111
MR. KAHLER MARTIONSON
REGIONAL DIRECTOR
U.S. FISH AND WILDLIFE SERVICE
LUITE 1692
LLOYD 500 BLDG.
500 N.E. MOLTNOMAH STREET
PORTLAND, OR 97232
SIERRA CLUB—VENTANNA CHAPTER
P.O. BOX 5667
CARMEL, CA 93921
MS. LINDA NAGEL
P. G. & E.
345 MISSION STREET
ROOM 2820
SAN FRANCISCO, CA 94106
EEENA HUFWITZ
7915 EMPIRE GRAEE
SANTA CRUZ, CA 95060
MR. RICHARD L. WOOD
1990 N. CALIFORNIA BLVD., #444
WAINUT CREEK, CA 94596
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MS. CHRISTINE A. KAHR
277 HIDDEN GLEN DRIVEMS.
SANTA CRUZ, CA 95060
MR. GORDON CALL
22275 DE ANZA CIRCLE
CUPERTINO, CA 95014
MR. TONY RYALS
875 FANNING GRACE
BEN LOMOND, CA 95005
MS. DIANE LIVINGSTONE
P.O. BOX 2910
SANTA CRUZ, Q\ 95063
MS. JAN KARWIN
121 EASTERBY AVEflUE
SANTA CRUZ, C\ 95060
JANE WEED
509 SEASIDE STREET
SANTA CRUZ, CA 95060
MR. GLENN SPECHT
3070 W. IEDYARD WAY
APTOS, CA 95003
MR. RALPH KENWORTHY
P.O. BOX 3111
MODESTO, CA 95353
MR. UAIi«CE 1-1. E&LE
2200 DELAWARE AVENUE
SANTA CRUZ, CA 95060
Helphingstine: Fish
reading/file
draft 4/9/80
HELP-4/9 Disc 2
MS. CATHERINE CALL
138 SHELTER IAGOON DRIVE
SANTA CRUZ, CA 95060
MR. BILL QUEALY
239 WAINUT
SANTA CRUZ, CA 95060
MR. RDNOLD POMERANTZ
509 SEASIDE STREET
SANTA CRUZ, CA 95060
MR. ROBERT HALL
107 POST
SANTA CFUZ, CA 95060
MR. ISDN E. ELLIS
TEAMSTERS UNION 912
P.O. BOX 591
WATSONVILLE, CA 95076
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TABLE OF CONTENTS
Page
CHAPTER 1 - INTRODUCTION 1
CHAPTER 2 - SUMMARY OF FACILITIES PLANNING PROCESS 5
Facilities Plan and EIS/EIR Preparation 5
City's Plan of Action 8
Major Environmental Issues and Their Status 9
Marine Discharge Impacts 9
Encroachment on Nearys Lagoon Wetland 10
Wastewater Reclamation, Recycling 11
Costs 13
Growth Impacts 13
CHAPTER 3 - RESPONSE TO COMMENTS ON THE DRAFT EIS/EIR 19
Introduction 19
Response to Written Comments 19
Advisory Council on Historic Preservation 22
U. S. Department of the Army, Corps of
Engineers, San Francisco District 25
U. S. Department of Interior, Office of
the Secretary 30
Association of Monterey Bay Area Governments 34
California Archeological Site Survey -
Archeological Regional Research Center 46
California Coastal Commission - Central
Coastal Regional Commission 56
California Department of Fish and Game 71
California Department of Transportation 73
California Office of Historic Preservation 76
California Regional Water Quality Control
Board - Central Coast Region 80
California State Water Resources Control
Board 83
Santa Cruz County Board of Supervisors -
Gary A. Patton 86
Santa Cruz County Community Resources
Agency 91
Donald Cleveland 94
Jack E. Collier 99
William Doyle 103
Ronald Pomerantz - Santa Cruz City Energy
and Urban Services Task Group 115
Billy Quealy 123
Tony Ryals 128
Shelter Lagoon Association 133
Thrust IV 141
Jane T. Weed - Energy Action of Santa Cruz 146
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Page
Response to Oral Comments 147
D. L. Cleveland 147
Norman S. Lezin 14 8
Bill Bahn 148
William Paiss 148
David Bockman 150
Wallace M. Dale 154
William Doyle 154
Ralph Kenworthy 155
Deena Hurwitz 155
Leon E. Ellis 156
Jack Collier 156
Diane Livingstone 157
Jane Weed 157
Jan Karwin 158
Ronald Pomerantz 15 9
Glenn Specht 162
Robert Hall 166
Bill Quealy 166
Tony Ryals 167
Jerry Busch 16 8
Supplemental Analyses Prepared in Response
to General Comments 170
Update of Population Discussion 170
Mitigation of Wetland Loss 176
Sludge Disposal Alternatives 177
Energy Consumption 180
Wastewater Reclamation 182
The New or Innovative Alternatives 184
BIBLIOGRAPHY 19 3
References 193
Personal Communications 194
LIST OF REPORT PREPARERS 195
ABBREVIATIONS AND ACRONYMS 196
APPENDIX A - PUBLIC HEARING TRANSCRIPT 197
APPENDIX B - LIST OF PROJECT BOARD OF CONTROL AND
INTERAGENCY ADVISORY COMMITTEE MEMBERS 289
APPENDIX C - ORIGINAL LIST OF PROJECT ALTERNATIVES -
IMPACT ANALYSIS AND SCREENING RATIONALE
291
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1
2
3
4
5
6
7
8
9
1
2
3
Page
3
14
15
88
172
173
178
179
189
190
134
137
138
LIST OF TABLES
List of Individuals, Agencies/ and Groups
Commenting on the Draft EIS/EIR
Alternative Project Costs - Present Worth
in Millions of Dollars
Service Area Population Projections - Pro-
posed Wastewater Facilities Capacities
Estimated Annual Service Costs of Alterna-
tives in Dollars
Service Area Populations in EIS/EIR
Projected Effects of Growth Management
Systems on Population Growth in Santa
Cruz County
Solid Waste Resource Recovery Processes
Selected for First-Stage Screening
Present Worth Cost for Aquaculture Treatment
Breakdown of Capital Costs for Aquaculture
Treatment
LIST OF FIGURES
Relationship of Alternative OD^ Treatment
Plant Expansion to Adjacent Land Uses
Alternative ODi^ Site Cross Sections
Alternative OD^B Site Cross Sections
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Chapter 1
INTRODUCTION
In June 197 9 the U. S. Environmental Protection Agency
(EPA), Region IX, and the City and County of Santa Cruz jointly
issued a Draft Environmental Impact Statement (EIS) (according
to the National Environmental Policy Act of 1969) and Draft
Environmental Impact Report (EIR) (according to the California
Environmental Quality Act of 1970) on the Santa Cruz Areawide
Wastewater Facilities Plan. The EIS/EIR was filed with the
State Clearinghouse (State Clearinghouse No. 79070310) and
with the Council on Environmental Quality (CEQ) (EIS Order No. 90599)
and circulated for review among various federal, state and
local agencies, as well as firms, organizations and concerned
individuals.
On August 29, 1979 a public hearing was held in the
City of Santa Cruz Council Chambers to receive comments on
the Draft EIS/EIR. This hearing was well attended and comments
were received from a large number of individuals. A complete
list of individuals, agencies and groups that submitted either
written or oral comments follows this section (Table 1).
A complete transcript of the public hearing is included as
Appendix A. This document has been prepared to respond
to all comments received. When combined with the Draft EIS/EIR,
it constitutes the Final EIS/EIR in accordance with CEQ guide-
lines 40 CFR 1500, EPA regulations 40 CFR 6, and California
Administrative Code Regulations, Title 14, Division 6.
The wastewater facilities plan and the Draft EIS/EIR
analyzed a number of alternative solutions to the wastewater
treatment needs of the Santa Cruz area. This included the
'no action" option among others. Many of the comments expressed
support for a particular alternative or particular approach
to wastewater management. Other comments focused on des-
criptions of impacts and presentation of background data.
The major issues raised by public comment are as follows:
o Strong support was expressed for wastewater reclamation,
energy conservation and reuse or recycling of waste-
water treatment by-products. Treatment and discharge
without reuse was severely criticized by numerous
commentors.
o Local industrial and labor representatives voiced
support for primary treatment alternatives due to
the predicted high annual costs of secondary treatment
options. Fears of layoffs and industrial plant
closures were expressed.
1
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o , Opposition to further expansion of wastewater treatment
facilities in Nearys Lagoon was expressed by local
residents, government agencies and homeowner repre-
sentatives. More emphasis on local operational
impacts at Nearys Lagoon was requested.
o Further consideration of the indirect impact of
nonreclamation alternatives was requested. The
financial and environmental impacts of developing
new water supplies for Santa Cruz were specifically
mentioned as areas of concern.
o Numerous commentors requested updating of data used
in the Draft EIS/EIR; this included population and
land use information and descriptions of legal and
regulatory influences on the project.
o Serious consideration of the longer ocean outfall
alternatives was requested; the longer outfalls
could provide an extra margin of safety from con-
tamination of the Santa Cruz shoreline.
o The pros and cons of primary versus secondary treat-
ment for deep water marine discharges were discussed.
o The adequacy of the archeological impact analysis
was questioned.
This Final EIS/EIR is divided into two main sections.
The following chapter summarizes the entire facilities planning
and environmental assessment process as conducted for the
Santa Cruz wastewater project. Alternatives considered,
engineering recommendations and the city's proposed plan
of action are all described. The second major chapter
presents all comments received on the Draft EIS/EIR and offers
responses to those comments. The format for this comment
and response section is described in the introduction to
the chapter. A list of references cited, a list of report
preparers and several appendices are included at the back
of the document.
2
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Table 1. List of Individuals, Agencies and Groups
Commenting on The Draft EIS/EIR
Federal Agencies
Advisory Council on Historic Preservation
U. S. Department of the Army, Corps of Engineers,
San Francisco District
U. S. Department of the Interior, Office of the Secretary
State and Regional Agencies, Entities
AMBAG - Association of Monterey Bay Area Governments
California Archeological Site Survey - Archeological
Regional Research Center
California Coastal Commission - Central Coastal Regional
Commission
California Department of Fish and Game
California Department of Transportation
California Office of Historic Preservation
California Regional Water Quality Control Board - Central
Coast Region
California State Water Resources Control Board - Division
of Water Quality
Local Agencies
Santa Cruz County Board of Supervisors - Gary A. Patton
Santa Cruz County Community Resources Agency
Individuals and Organizations
Bill Bahn - Leather Workers Local L-122
David Bockman - Sierra Club
Jerry Busch - Greenbelt Committee
Gordon E. Call - Thrust IV
Donald Cleveland - Shelter Lagoon Association
Jack E. Collier
Wallace M. Dale - Lipton Company
William Doyle
Leon E. Ellis - Teamsters Local No. 912
Robert Hall
Deena Hurwitz - People for a Nuclear Free Environment
Jan Karwin - Santa Cruz League of Women Voters
Ralph Kenworthy - John Inglis Frozen Foods Company
Norman S. Lezin - Salz Leathers
Diane Livingstone
William Paiss - People for Responsible Science
Ronald Pomerantz - Santa Cruz Energy and Urban Services
Task Group
Bill Quealy - Santa Cruz Nutrient Energy Action Committee
Tony Ryals - Nutrient Energy Resources Committee
Shelter Lagoon Association
Glenn Specht
Jane Weed - Energy Action of Santa Cruz
3
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Chapter 2
SUMMARY OF FACILITIES PLANNING PROCESS
Facilities Plan and EIS/EIR Preparation
Planning for Santa Cruz wastewater facilities improvements
began in October 1975 when the City and County of Santa Cruz
contracted with Brown and Caldwell, an engineering firm, to
prepare a wastewater facilities plan. The planning effort
was prompted by the need to bring the Santa Cruz wastewater
discharge into compliance with the mandates of the Federal
Water Pollution Control Act Amendments of 1972 (FWPCA) and
the Caiitornia Ocean Plan. The existing city wastewater
treatment plant effluent discharge did not meet the secondary
treatment standards of the FWPCA and the location and hydraulic
character of the existing nearshore outfall was not capable
of meeting ocean plan receiving water quality standards.
The Santa Cruz wastewater treatment plant is a 21-million-gallon
per-day (MGD) average dry weather flow capacity facility
providing primary treatment. The discharge point is appro-
ximately 2,000 feet offshore at a depth of 40 feet and is
about 1 mile west of Point Santa Cruz.
The FWPCA established a process by which local entities
could plan for, design and construct required wastewater
facilities with the aid of sizeable federal and state grants.
EPA was given federal responsibility to establish and enforce
the FWPCA water quality guidelines and to manage the grant
program. In California, many of the enforcement and grant
responsibilities have been delegated to the State Water
Resources Control Board (SWRCB) and the Regional Water Quality
Control Boards (RWQCBs). EPA determined significant environ-
mental impacts would result from the implementation of this
project, and therefore, decided that an EIS needed to be
prepared to comply with the mandate of the National Environ-
mental Policy Act (NEPA). An EIR was required to be prepared
on the planned facilities in order to conform to state environ-
mental law (the California Environmental Quality Act - CEQA). In
1976, the City and County of Santa Cruz contracted
with Jones & Stokes Associates, Inc., of Sacramento to prepare
a combined EIS/EIR to satisfy the EPA and SWRCB environmental
reporting requirements. The Santa Cruz EIS/EIR has been
prepared simultaneously with the wastewater facilities plan
m what is referred to as the "piggyback" process.
Once engineering and environmental consultants had been
selected, the planning process began in earnest. Two committees
were formed at the outset to guide the planning process.
The Board of Control (BOC) was composed of local city and
county government representatives and consultant representatives.
The Interagency Advisory Committee (IAC) was composed of
5
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federal, state, regional and local government regulatory and
planning agencies. A full listing of BOC and IAC members
is included as Appendix B. Once a month these two groups
met in advertised, open public meetings to discuss facilities
planning and environmental review progress. These meetings
continued regularly from April 1976 through May 1978.
The process of developing alternatives to solve the
wastewater treatment and disposal problems of the Santa Cruz
area started with preparation of the Central Coastal Water Quality
Control Plan (SWRCB, 1975). This document analyzed different
approaches to wastewater management in the basin and established
recommendations and guidelines to be utilized in formulating
specific wastewater treatment and disposal systems for the
various communities in the Santa Cruz area. Prom this baseline,
the work plan for the current facilities planning was developed
by Brown and Caldwell in cooperation with the City and County
of Santa Cruz and the SWRCB. The work plan stipulated that
a range of alternative treatment and disposal/reuse methods
would be analyzed to determine their feasibility in the Santa
Cruz area. Treatment to be considered included advanced
primary, biological secondary, physical-chemical, and land
treatment. Reuse/disposal methods identified included ocean
discharge, agricultural irrigation, groundwater recharge,
irrigation of public lands, industrial reuse and stream flow
augmentation.
The initial work on alternatives concentrated on the
ocean disposal option. Location and design of an improved
ocean outfall was given a thorough engineering and environ-
mental evaluation by the project consultants. The compiled
analyses were presented at a public workshop in Santa Cruz
on November 10, 1976 to gain public input for the analysis
and selection process. Results of the outfall analysis are
presented in the Summary Report Oceanographic Reconnaissance
prepared by Brown and Caldwell (1976d). A summary of the
public workshop was also prepared by Brown and Caldwell (1977).
As a second step to identifying the most viable project
alternatives, Brown and Caldwell prepared and distributed
a Strategy for Wastewater Management Alternative Formulation
(Brown and Caldwell, 1977a); this outlined a methodology for
developing alternatives out of a list of engineering and
environmental issues that had been identified in the plannina
process. Inputs from the public workshop and monthly BOC
and IAC meetings aided in developing the list of issues.
From this issues analysis Brown and Caldwell developed an
initial list of 23 project alternatives. These are presented
in Appendix C. General layouts, engineering feasibility
analyses and cost estimates were prepared for all 23 alter-
natives and an environmental analysis was conducted by
6
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Jones & Stokes Associates {see Appendix C). A summary of
this material was distributed to public agencies, community
and citizen groups and known interested parties, and on
August 10, 1977, a second public workshop was conducted.
The status of the project was discussed and each of the
2 3 project alternatives was described. The public was then
given a chance to ask questions and suggest additional approaches
to wastewater treatment and disposal. A summary of the alter-
natives workshop proceedings was subsequently prepared by
Brown and Caldwell and made available to the Board of Control
and other interested parties.
Following the workshop Brown and Caldwell continued
their alternatives screening process and at the August 1977
BOC meeting asked for authorization to proceed on a detailed
analysis of the five alternatives they felt were most feasible.
Reasons for elimination of those not selected were discussed
in detail (see Appendix C). The five alternatives recommended
for further consideration included OD., OD^, OD/RE^, and OD/RE
(see below; no action would also be considered). Of these,
OD7 had n6t been included in the original 23 alternatives
derived by Brown and Caldwell and presented at the public
workshop. OD_ proposes use of an advanced primary or so-
called "marin6 secondary" treatment level and discharge to
the ocean. The marine secondary treatment would be less
than the federal requirement under the FWPCA, which stipulates
30 mg/1 effluent limitations on BOD and suspended solids.
However, Brown and Caldwell felt that pending legislation
in the U. S. Congress might change these effluent limitations
to allow a treatment of less than the current secondary for
ocean disposal in certain cases. For this reason, they
encouraged consideration of 0D7« The EPA, however, felt
that because this alternative was not legal under U. S. law,
at that time, its study could not be funded under the Clean
Water Grant Program. Subsequent discussions between EPA,
the SWRCB, the City and County of Santa Cruz and Brown and
Caldwell resulted in elimination of 0D_ as an alternative
for detailed consideration. It was concluded that the no-
project alternative, which must be considered under state
and federal EIS/EIR guidelines, would provide the opportunity
to analyze a treatment level of less than federal secondary.
This approach was accepted by the BOC in September 1977;
the facilities engineers and environmental consultants were
therefore authorized to investigate alternatives OD., OD.-,
Od/RE,, 0D/RE7, and no project in detail in the facilities
plan and EIS/EIR.
OD]_ - Upgrade primary treatment plant to secondary
treatment at existing Nearys Lagoon site;
construct extended ocean outfall.
OD4B - Construct new secondary treatment plant west of
Santa Cruz and new ocean outfall near Terrace
Point; abandon Nearys Lagoon plant.
7
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OD-y - Upgrade primary treatment plant to advanced primary
treatment at existing Nearys Lagoon site; construct
extended ocean outfall.
OD/RE5 - Upgrade Nearys Lagoon treatment plant and outfall
as in OD^; construct advanced waste treatment
plant north of Watsonville for seasonal reclama-
tion of Santa Cruz effluent and irrigation of
Pajaro Valley cropland.
OD/RE7 - Construct new secondary treatment facilities and
outfall at Santa Cruz as in Alternative OD^ or
OD4B/ add advanced waste treatment to Watsonville
plant for reclamation and use as seawater intrusion
barrier near mouth of the Pajaro River.
Passage of PL 95-217 (the Clean Water Act of 1977) in
November 197 7 amended the FWPCA to allow coastal communities
to apply for modification of the secondary treatment require-
ment. Even though this change came near the end of the
facilities planning effort, the project BOC recommended that
an advanced primary ocean discharge be reinvestigated and
a waiver application be prepared. Because federal regulations
and policy implementing the Clean Water Act had yet to be
finalized, the EPA stated that consideration of an alternative
with less than secondary treatment should not be included
in the Draft EIS/EIR. Therefore, the advanced primary dis-
charge alternative (OD7) was discussed in the facilities
plan but only mentioned briefly in the Draft EIS/EIR
issued in May 1979. The facilities plan, issued in May 1978,
recommends implementation of alternative 0D_ if the application
for modification of secondary treatment is successful. The
City of Santa Cruz independently contracted with Jones &
Stokes Associates to prepare a supplement to the EIR portion
of the Draft EIS/EIR in order to discuss the environmental
implications of 0D7. The city felt this was necessary to
comply with the alternatives coverage required by CEQA. This
supplement was circulated for public review at the same time
as the Draft EIS/EIR. Public hearings on the Draft EIS/EIR
and the EIR supplement were held in Santa Cruz on August 29,
1979.
City's Plan of Action
In September 1979, the City of Santa Cruz submitted its
application for modification of secondary treatment to EPA.
The city's current plan of action calls for proceeding with
design work on the engineer's recommended ocean outfall route
(1C) and treatment plant modifications at Nearys Lagoon.
If modification of the secondary treatment requirement is
granted, the OD7 facilities will be constructed; if not,
the ODia facilities will be constructed. In either case,
8
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the treatment facilities are planned to remain at the Nearys
Lagoon site. A grant offer to proceed with design of the
extended outfall and treatment modifications for both second-
ary and advanced primary treatment facilities will be made
after this Final EIS/EIR has been certified as adequate by
the Santa Cruz City Council. A determination on the waiver
application may not be completed for another year.
Major Environmental Issues and Their Status
Alternatives 0D_ and 0D-A have been recommended by
Brown and Caldwell and are presently the City of Santa Cruz's
preferred alternatives. Both are described in depth in the
final project report (Brown and Caldwell, 1978c). The following
paragraphs briefly summarize the major environmental issues
raised during the planning process with regard to these alter-
natives .
Marine Discharge Impacts
The effect of wastewater discharges on the marine environ-
ment and shoreline water uses continues to be controversial.
The scientific community remains split in recommending the
most appropriate type of wastewater treatment for marine
discharges. Federal law (PL 95-217) still requires biological
secondary treatment unless the discharger can demonstrate
that in his case use of lesser treatment is sufficient and
that a modification of the secondary treatment requirement
is appropriate. This requirement was established after serious
consideration of impacts on marine biota. Analyses conducted
by Brown and Caldwell indicate that the treatment and disposal
planned for Alternative OD^ are capable of meeting both
PL 95-217 and revised State Ocean Plan discharge requirements.
The proposed advanced primary discharge of Alternative OD7
is expected to meet revised State Ocean Plan standards but
it is as yet unclear whether this is acceptable under federal
law (PL 95-217).
The impact on marine organisms is similarly clouded.
Elimination of the present nearshore Santa Cruz discharge
would have obvious public health and aesthetic benefits.
The present outfall creates surface discoloration visible
from the bluffs along the Santa Cruz shoreline, and recent
monitoring along the beaches near the outfall indicate
coliform levels exceed those acceptable for shellfish harvesting
(Brown and Caldwell, 1979). It would also remove any influence
on nearshore biota, even though predischarge and 301(h)
monitoring near the existing outfall failed to detect a
significant influence of that discharge on biota in the
vicinity. The new outfall would provide much greater effluent
dilution at a point nearly 1 mile offshore, in 100 feet of
water. Brown and Caldwell (1979) have predicted that this
9
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new discharge would have even less likelihood of producing
a discernible impact on marine organisms. Therefore, the
change in discharge locations should have a net positive
influence on the marine environment. There are still con-
cerns, however, over the chronic effects of certain potentially
toxic wastewater constituents on marine organisms. This
includes metals such as chromium and cadmium, total chlorine
residual and other man-made compounds that are infrequently
or never monitored. These concerns persist, whether waste-
water treatment is primary or secondary, because data sup-
porting or alleviating claims of potential damage to marine
biota are often conflicting and usually insufficient.
The new extended outfall is proposed as alleviation
from existing and protection from future potential acute
and chronic impacts on marine biota. The protection is pro-
vided in the form of added dilution. The proposed treatment
improvements (secondary or advanced primary) will reduce
the amount of pollutants, including toxic materials in the
effluent. Because of the relative unpredictability of impacts,
the city's new waste discharge permit will require an extensive
monitoring program in the vicinity of the outfall. Draft
versions of the monitoring program have been included in Santa
Cruz's 301(h) modification application. Before a new permit
is issued, the potential impacts of primary and secondary
effluent will receive further scrutiny in the secondary
treatment waiver application process.
Encroachment on Nearys Lagoon Wetland
EPA guidelines for the discharge of dredged or fill
material recognize that "the degradation of aquatic
resources by filling operations in wetlands is considered
to be the most severe environmental impact" (40 CFR 230,
September 5, 1975). In recognition of the value of
Nearys Lagoon as a wetland, provision of secondary facili-
ties at Nearys Lagoon was considered in two ways in the
Project Report and Draft EIS/EIR (pages 303 and 365). They
were each developed to simultaneously permit implementation
of the OD]_ alternative (continued location of wastewater
treatment facilities at Nearys Lagoon) and to mitigate the
impacts to Nearys Lagoon. These two alternatives are:
1) establishment of replacement wetland adjacent to the lagoon,
or 2) location of the secondary treatment facilities on vacant
city-owned property northeast of Nearys Lagoon.
In consultations between the U. S. Fish and Wildlife
Service, the City of Santa Cruz, the SWRCB, and EPA, con-
ducted since the issuance of the Draft EIS/EIR, the U. S.
Fish and Wildlife Service has advised that it finds it pre-
ferable that the split-plant option of Alternative ODi be
10
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constructed rather than to expand the existing facilities
farther into Nearys Lagoon. The U. S. Fish and Wildlife
Service has advised that the split-plant option would result
in the least disturbance to the wetland habitat of Nearys
Lagoon. This disturbance would be short-term and limited
to the period required for construction of wastewater pipe-
lines across the lagoon.
If the other option of Alternative OD^ is implemented,
it would result in the loss of possibly as much as 2-3 acres
of wetland. In order to mitigate this loss a compensating
adjoining new wetland of equal value would be created on
city property northeast of and immediately adjacent to Nearys
Lagoon. The city would ensure that this replacement wetland
would be established with native plant species similar to
those located within the construction site. If the Cali-
fornia Department of Fish and Game's interpretive guidelines
are adopted, which require a replacement ratio of possibly
as much as 4:1, as much as 8-12 acres of new wetland might
have to be created to compensate for the loss of lagoon wetland.
Nearys Lagoon is a city park. The city would provide
for care of the reestablished plants and normal park mainten-
ance. Public access to a portion of the wetlands would be
provided as at the existing park.
Measures such as boundary levees or silt screens would
be used to limit the amount of turbidity created in lagoon
waters during construction.
Final determination of which OD^ option will be constructed
will be made after preliminary design information is available
and a U. S. Fish and Wildlife Service wetland evaluation
has taken place. The city, EPA, and the SWRCB will then
consider the findings of the U. S. Fish and Wildlife Service
and consultant engineers (Brown and Caldwell) evaluations.
This will include consideration of the value of the wetland,
the cost differences between OD^ options, the possible opera-
tion and maintenance problems of a split-plant facility and
the reliability of wastewater treatment from the split-plant
and single-plant options. Selection between the two options
will then be made based on the above and any other relevant
factors.
Wastewater Reclamation, Recycling
Considerable public support for wastewater reclamation
has been voiced throughout the Santa Cruz facilities planning
process. This was especially evident at the public hearing
on the Draft EIS/EIR. Nonetheless, the city is pursuing
plans that would not include reclamation of Santa Cruz's
wastewater. Both alternatives still being considered call
for wastewater disposal to the ocean via a deepwater outfall.
11
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The major reasons for this lack of reclamation are high
cost and lack of sufficient demand for reclaimed water. State
and federal water quality and public health regulations require
a high degree of treatment prior to most methods of reuse.
This placed the cost of reclamation alternatives considered
by Brown and Caldwell well above simple treatment and ocean
disposal. Industry and labor representatives from the Santa
Cruz area strongly opposed alternatives that would greatly
increase treatment system user costs. Brown and Caldwell's
search for a reclamation market indicated that only the Pajaro
Valley agricultural area could utilize all of Santa Cruz's
wastewater. The cost of treating and then transporting waste-
water that distance proved not to be cost-effective (Brown
and Caldwell, 1978c, pages 9-15 to 9-17). If the smaller
local markets were utilized, the cost would still be high,
as the advanced treatment would be necessary and the extended
outfall would have to be constructed to dispose of the water
not reused.
The City of Scotts Valley, with a much smaller wastewater
flow, plans to reclaim and reuse its wastewater within the
Santa Cruz area by irrigating a golf course and surrounding
greenbelt areas. In addition, the Santa Cruz facilities
plan recommends further consideration of reclamation by Watson-
ville, the cause being development of a seawater intrusion
barrier along the coast in the Pajaro Valley. While the
proposed project does not immediately implement a reclamation
scheme, construction of an extended outfall and improvements
in treatment facilities would be needed if reclamation is
implemented and so does not preclude later reclamation and
reuse of the wastewater.
A major task in the facilities planning process was
to investigate the sludge reuse potential for Santa Cruz.
Brown and Caldwell (1978) produced a document that thoroughly
analyzed the costs and feasibility of alternative sludge
reuse and disposal methods. The study area included all
of Santa Cruz County and the northern portion of Monterey
County. The study recommended that sludge from the Santa
Cruz plant be processed and dewatered at the Nearys Lagoon
plant site and be disposed of in the Santa Cruz landfill.
Several commentors on the Draft EIS/EIR suggested that
certain means of sludge reuse would be more beneficial than
sludge disposal. This included composting and the use of
earthworms. While use of earthworms for processing sewage
sludge has not yet been operated on a full-scale basis, it
is being tried in a pilot project in San Jose. The sludge
processing now being used at the Santa Cruz plant is similar
to that used in San Jose prior to vermicomposting. If Santa
Cruz feels that vermicomposting or some other means of com-
posting is worthy of consideration, it could be initiated
on an experimental basis now. This would require some addi-
tional planning, however, to estimate costs and determine
whether a market exists or could be developed for the com-
posted sludge. Currently, Santa Cruz has no plan to embark
on a composting project.
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Costs
Project capital costs and estimated user costs are an
integral part of any environmental evaluation. EPA grant
guidelines require that detailed economic evaluations be
a part of the facilities planning and EIS review processes.
They also require that grant funds be allocated only to the
most cost-effective projects unless unusual circumstances
justify some other approach.
The facilities plan economic analysis indicated that
Alternative OD. would have the lowest total present worth
cost ($44.29 million) of all the secondary treatment options.
This is the option selected by Santa Cruz for implementation
unless it is granted a modification of the secondary treat-
ment requirement. OD^ also has the lowest estimated residential
user cost (about $86 per year in the City of Santa Cruz)
and industrial user cost of the secondary treatment alternatives.
A summary of alternative project costs is included in
Table 2. The numbers should be used for comparison only.
Costs for the selected project will eventually be revised
and updated during the design process. Capital costs and
user fees will undoubtedly change at that time. If Santa
Cruz's modification of secondary treatment application is
favorably acted upon, it is expected that an advanced primary
alternative (OD7) will be implemented. Anticipated user
costs for Alternatives and OD7 are presented in
Table 4 of this document.
Growth Impacts
Population Basis for Planning. Population growth has
become a significant political and environmental issue in
the Santa Cruz area in recent years. Local desires to better
control and manage growth resulted in the passage in City
Measure 0 and County Measure J in 1978. These actions have
not been reflected in the Wastewater facilities planning
to date because they occurred at the very end of the planning
process.
Brown and Caldwell's facilities planning and the impact
analysis presented in the EIS/EIR were conducted using independent
population forecasts prepared specifically for this planning
effort by Gruen Gruen + Associates. These numbers are shown
in Table 3. The 10- and 20-year planning horizons were used
by Brown and Caldwell to predict waste flows and calculate
facilities sizes, as required by facilities planning guidelines.
The table presents three sets of population totals,
each with a slightly different derivation and significance.
The Gruen Gruen + Associates service area total includes
all persons that might be expected to contribute waste flows
13
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Table 2. Alternative Project Costs -
Present Worth in Millions of Dollars
odia
odib
0D4B
00 7
od/re5a2
°d/Re5b2
OD/RE.
Stage 1 capital cost
31.52
33.04
44.76
19.37
49.11
71.90
21.9
Stage 2 capital cost
2.74
2.74
4.12
1.60
4.8
5.66
.7
Total capital cost
34.26
35.78
48.88
20 .97
53. 91
77.56
22.6
Operation and Maintenance1
10.03
10.28
10.91
8.63
10. 48
13.90
23.6
Total present worth cost
44.29
46.06
59.79
29.60
64. 39
91.46
46.3
xFor 20 years of operation.
2Costs are just for reclamation portion of these alternatives; it does not include the cost of
improvements necessary at the Santa Cruz plant (44.29 million dollars for Alternative OD. ).
J.n
SOURCE: Brown and Caldwell, 1978, pages 9-13 and 9-15.
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Table 3
SERVICE AREA POPULATION PROJECTIONS
PROPOSED KAS1ENATER FACILIIIES CAPACITIES
1989
1999
UI
Ibtal Service Area
Population
Population used
for Facilities
Sizing*
Permanent
Nonpernanent
Student
Total
Permanent
Nonpermanent
Student
Total
Santa Cruz
37,390
12,370
6,220
55,980
46,530
16,260
7,270
70,060
East Clif f-Capitola
48,460
17,040
820
66,320
61,890
21,410
1,070
84,370
Aptos
18,560
17,090
220
35,870
25,430
21,220
280
46,930
La Selva
2,260
10,000
10
12,270
3,510
11,060
20
14,590
County Area A
4,070
980
30
5,080
5,100
790
30
5,920
Subtotal
110,740
57,480
7,300
-
142,460
70,740
8,670
-
175,520
118,040
221,870
151,130
D-100 PROJECTION FOR SANTA CPOZ GRANT FUNDABLE AREA
City of Santa Cruz
County - Aptos, Capitola/East Cliff
County Area A
Tbtal Grant Fundable Area Population
1976
1989
1999
37,653
55,485
67,801
47,035
69,310
84,697
2,524
3,720
4,5^3
87,212
128,515
157,041
~Note: Gruen Gruen + Associates population studies were used to plan the sizing of the proposed wastewater facilities,
consequently population projections double as planned facility capacity; nonpermanent population is not included
in Brown and Caldwell facilities sizing because their gpcd estimates for permanent population include an increment
for flows from nonpermanent population.
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to the treatment plant. This includes permanent, nonpermanent
and student segments of the population. The numbers used
by Brown and Caldwell to calculate facilities sizes are the
Gruen Gruen + Associates numbers minus the nonpermanent segment
of the population. Historically, nonpermanent population
has been excluded from design calculations because it is
difficult to estimate. Waste flow generation factors have
been established by dividing observed waste flows by permanent
population. This may seem to exclude the nonpermanent popu-
lation, but in fact any flow generated by this group is included
in the flow multiples applied to permanent residents. In
summary, even though Brown and Caldwell uses an apparently
lower population number to calculate future waste flows,
it does include capacity for the nonpermanent population
as well.
The third population total on the page is the grant-
fundable population. This is the maximum population for
which the SWRCB and EPA are willing to provide grant funds.
It was developed by the SWRCB using the California Department
of Finance D-100 projection for Santa Cruz County. Even
though the grant-fundable service area outlined by the SWRCB
is smaller than the facilities plan's proposed service area,
the grant-fundable population estimate is higher because
the D-100 growth rate is higher than that established by
Gruen Gruen + Associates. The purposes of this project is
to upgrade the existing primary wastewater treatment plant
(WWTP) to the secondary treatment level and to provide a
new ocean outfall. This project will not increase the existing
WWTP capacity. The City of Santa Cruz intends to construct
upgraded treatment facilities and a new deep ocean outfall
for the same capacity as their existing facilities, i.e.,
21 mgd (average dry weather flow). The grant eligible capa-
city will be determined by the SWRCB based upon the population
projections. The city will pay for those incremental costs
over that determined to be eligible by the SWRCB (approxi-
mately 16 mgd of the flow capacity, not the 21 mgd to be
constructed by the city).
Water Supply Implications. The growth being planned
for by the City and County of Santa Cruz will put additional
stresses on the area's fresh water supply. Santa Cruz was
severely affected by the 1975-1977 drought because of its
rather limited surface and groundwater resources. Existing
demand is rapidly approaching developed supply and saltwater
intrusion has already affected coastal aquifers in parts
of the county. The Draft EIS/EIR predicted that approximately
2 3,000 of a developed 25,000 acre-feet of annual supply would
be needed by 1989. This indicates that additional water
development must take place or some significant water con-
servation must be initiated during the 20-year time frame
of this wastewater planning effort or growth will be constrained.
16
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It is likely that the additional water demand will be
met by additional surface or groundwater development within
the Santa Cruz area. This likelihood was a point of concern
to many of the individuals commenting on the Draft EIS/EIR.
Air Quality Implications. The Santa Cruz-Monterey air
basin is already considered to be in violation of the national
ambient air quality standard for oxidant. This is true despite
a recent relaxing of the standard from 0.08 to 0.12 pphm of
ozone. Air quality projections developed by Brown and Caldwell
indicate that the violations will continue unless a signi-
ficant effort to reduce pollutant emissions occurs. In the
Santa Cruz area that means a significant effort must be made
to reduce automobile traffic, as autos are the major source
of oxidant emissions. The Association of Monterey Bay Area
Governments (AMBAG) is responsible for developing a plan
to reduce air pollution to acceptable levels in Monterey
and Santa Cruz Counties. They will soon be developing new
ambient air quality forecasts for the area based on revised
population estimates. These population estimates wili take
into account recent growth management planning being conducted
for Santa Cruz. The air quality forecasts will be accompanied
by a plan of specific local actions that can bring local
air quality into compliance with state and national standards.
The City and County of Santa Cruz will be called upon to
participate in and implement some of these mitigating actions
in order to compensate for the growth occurring in their
jurisdictions. This local nonattainment plan will be made
part of the state's revised implementation plan, which is
expected to be submitted to EPA for approval in 1981.
17
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Chapter 3
RESPONSE TO COMMENTS ON THE DRAFT EIS/EIR
Introduction
This chapter provides written responses to all pertinent
questions and comments received on the Draft EIS/EIR. It
is organized into three main sections. The first provides
responses to written comments that must be considered individ-
ually. In general these responses are brief. Each letter
of comment is presented and each comment within the letter
is given a number. Immediately following each letter, a
corresponding list of numbered responses is presented. The
second section presents oral testimony and responses. Only
those portions of testimony requiring some response are presented.
In this case, each person's testimony is presented and pertinent
comments are given a number. Correspondingly numbered responses
follow each person's commentary. The third section deals
with written or oral comments that could not be responded
to in brief statements. This includes requests for further
impact analysis or major data revision and updating. In
most cases these narratives respond simultaneously to a number
of similar comments on the Draft EIS/EIR.
Response to Written Comments
The following letters of comment have been grouped into
several categories including federal, state, and local agencies,
and individuals and organizations. Each letter is followed
by responses to pertinent questions and comments.
19
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Advisory
Council On CUS-lSty I
Historic ¦'EGEiyEQ
Preservation REGION I;
¦I'lr1-' d :.f('].
1522 K Street NW.
Washington D.C.
20005 Reply to: P. O. Bar.
Dcavor, ColvrrAo 88525
June 18, 1979
Mr. Paul De Falco, Jr.
Regional Administrator
Environmental Protection Agency
Region IX
215 Fremont Street
San Francisco, California 9^105
Dear Mr. De Falco:
This is to acknowledge receipt of the draft environmental
statement for the Santa Cruz Areawide Wastewater Facilities
Plan, California, on June 18, 1979- We regret that we
will be -unable to review and comment on this document
in a timely manner pursuant to Section 102(2)(C) of the
National Environmental Policy Act of 19&9•
1. Nevertheless, the Environmental Protection Agency is
reminded that, if the proposed undertaking will affect
properties' included in or eligible for inclusion in the
National Register of Historic Places, it is required by
Section 106 of the National Historic Preservation Act
of 1966 (16 U.S.C. Sec. 470f, as amended, 90 Stat.
1320) to afford the Council an opportunity to comment
on the undertaking prior to the approval of the expenditure
of any Federal funds or prior to the issuance of any
license. The Council's regulations, "Protection of
Historic and Cultural Properties" (36 CFR Part 800.lt)
detail the steps an agency is to follow in requesting
Council comment.
Generally, the Council considers environmental evaluations
to be adequate when they contain evidence of compliance
with Section 106 of the National Historic Preservation
Act, as amended. The environmental documentation must
demonstrate that either of the following conditions
exists:
20
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Page 2
Mr. Paul De Falco, Jr.
Santa Cruz Wastewater Facilities Plan
June 18, 1979
1. No properties included in or that may be
eligible for inclusion in the National Register are
located within the area of environmental impact, and
the undertaking will not affect any such property. In
making this determination, the Council requires:
—evidence that the agency has consulted the latest
edition of the National Register (Federal Register,
February 6, 1919, and its monthly supplements)j
—evidence of an effort to ensure the identification of
properties eligible for inclusion in the National
Register, including evidence of contact with the State
Historic Preservation Officer, whose comments should be
included in the final environmental statement.
2. Properties included in or that may be eligible
for inclusion in the National Register are located
within the area of environmental impact, and the undertaking
will or will not affect any such property. In cases
where there will be an effect, the final environmental
statement should contain evidence of compliance with
Section 106 of the National Historic Preservation Act
through the Council's regulations, "Protection of
Historic and Cultural Properties".
Should you have any questions, please call Jane King at
(303) 23h-h9h6, an FTS number.
of Review and Compliance
21
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Advisory Council on Historic Preservation
1. In order to comply with Section 106 of the National
Historic Preservation Act of 1966, the National Register
of Historic Places was checked to determine if any
properties included on that list might be impacted by
the proposed wastewater facilities. The February 6,
1979 Federal Register (vol. 44, no. 26), which contains
a full listing of designated places, and monthly and
weekly updates through October 23, 1979 (vol. 44, no. 206),
were checked and no designated sites or pending nominations
were found to be in the area of impact. During prepara-
tion of the Draft EIS/EIR all proposed facilities sites
being actively considered for use by the City of Santa
Cruz were field surveyed by two professional archeo-
logists. This field survey and a subsequent records
search investigated the potential for impacts on archeo-
logical and historic resources and determined that the
recommended alternative is not believed to have the
potential to affect any cultural resources. The SWRCB
staff archeologist would be called immediately if any
archeological resources were uncovered during the
construction process.
The original archeological report prepared by Ann S.
Peak and Associates and the Draft EIS/EIR were forwarded
to the State Historic Preservation Officer in California.
The letter of comment from the California Office of
Historic Preservation is included in this Final EIS/EIR.
It did not identify any additional properties eligible
for inclusion on the National Register of Historic Places
in the areas of potential project impact.
22
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(M£'-/S-4)
DEPARTMENT OF THE ARMY
SAN FRANCISCO DISTRICT. CORPS OF ENGINEERS
211 MAIN STREET
SAN FRANCISCO. CALIFORNIA 94105
Aug 16 9 2s AM r7C
U.S.E.P.A.
REGION 3
COMMCKTR
SPNED-E
13 August 1979
2.
Mr. Paul DeFalco, Jr.
Regional Administrator, Region IX
U. S. Environmental Protection Agency
215 Fremont Street
San Francisco, California 94105
Dear Mr. DeFalco:
We have reviewed the joint EIS/EIR for the "Santa Cruz Wastewater
Facilities Plan prepared by your agency and the City of Santa Cruz.
Our comments follow:
a. A Department of the Army permit may be required for portions of
the proposed project, under Section 404 of the Clean Water Act and under
Section 10 of the River and Harbor Act. If there are any questions
regarding the permit process, please contact our Regulatory Functions
Branch at (415) 556-5966.
b. Clarification of Corps jurisdiction is required (page 255). The
possibility of the need for a Section 10 permit should be mentioned and
the limits of Corps Section 10 jurisdiction should be stated as being to
the line of Mean High Water (MHW).
c. Any work to be undertaken in wetland areas, such as Elkhorn and
Bennett Sloughs, Valencia Lagoon, and Ellicott Pond, should be avoided
if at all possible due to their unique biological value and productivity.
Any unnecessary alteration or destruction of such wetlands is considered
contrary to the public interest according to Corps regulations (33 CFR 320.4).
d. The following are corrections of those Corps of Engineers' hydrology
figures cited on page 206 of the subject report:
1.5 yr - 4,000 cfs
2.0 yr - 5,800 cfs
5.0 yr - 13,000 cfs
10.0 yr - 19,000 cfs
23
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SPNED-E
Mr. Paul DeFalco, Jr.
13 August 1979
These corrected figures are from the latest hydrology figures, developed
in 1973 for the local Flood Protection Insurance program. The 20-year,
50-year, and 100-year peak flows are accurate.
e. On page 301 it is stated, "The following table . . The table
does not follow, but precedes. The table should be numbered, then the
table could be properly referred to. Also, the text indicates that "Mitiga
tion measures . . . are listed in the left-hand column." This is incorrect
the measures are listed in the right-hand column,
f. The definition of floodplain given on page 453 should be general-
ized. We talk frequently about the 100-year floodplain. Therefore, the
definition should just indicate that a floodplain is an area periodically
subject to flooding.
Thank you for inviting our comments on the subject report.
Sincerely yours
2
24
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U. S. Department of the Army, Corps of Engineers,
San Francisco District
1. The City of Santa Cruz has applied for a permit under
Section 404 of the Clean Water Act in order to dispose
of dredged material when construction of an extended
ocean outfall is eventually undertaken. They will also
seek a 404 permit for construction in Nearys Lagoon
wetland should Alternative OD^a be implemented.
2. It is likely that a Section 10 (33 U. S. C. 403) permit
would be required for structures maintained along the
new ocean outfall alignment during construction, as
this route falls within navigable waters of the U. S.
The U. S. Army Corps of Engineers, San Francisco Office
has been contacted in this regard. The limits of Corps
Section 10 jurisdiction should be corrected to read
"up to the line of Mean High Water (MHW)".
3. The only wetland that would be affected by the project
now being pursued by the City of Santa Cruz is Nearys
Lagoon. The loss of at most 2-3 acres of wetland is
anticipated due to the implementation of Alternative ODj^.
If the city is successful in receiving a modification
of the secondary treatment requirement, none of the wet-
land will be lost. EPA will require mitigation of the
wetland loss. Refer to page 176 for further discussion
of this topic.
4. The flood frequency data presented on page 206 of the
Draft EIS/EIR should be revised to reflect the new
numbers presented in the Corps of Engineers' letter
of comment.
5. The errors in the text of paragraph 1, page 301 should
be corrected to indicate that the impacts table is
located on the preceding page and that mitigations are
listed in the right-hand column.
6. The definition of floodplain should be revised to read
"...that would be periodically subject to flooding".
25
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ER79/578
' 5y £.
G/Ofy
*4
CH£-i£H) 5
UNITED STATES
DEPARTMENT OF THE ir^E^IOR *
OFFICE OF THE SECRETARY ' '« 5i /?//
PACIFIC SOUTHWEST REGION
BOX 36098 . 450 GOLDEN GATE AVENUE
SAN FRANCISCO, CALIFORNIA 94102
(415) 556-8200
August 9, 1979
Mr. Paul DeFalco, Jr.
Regional Administrator
Environmental Protection Agency
215 Fremont Street
San Francisco, CA 94105
Dear Mr. DeFalco,
The Department of the Interior has reviewed the draft environmental
statement and report for Santa Cruz Areawide Wastewater Facilities
Plan, Santa Cruz County, California. Our general and specific
comments follow.
General Comments
In general, we are in support of projects that would result in
the reduction of pollutant inflow into coastal waters. However,
we have the following concerns with respect to the proposed project:
(1) The destruction of wetlands and riparian habitats; (2) an
approach which encourages dilution instead of pollutant removal,
and (3) the discharge of effluent to the ocean instead of wastewater
reuse.
Of the alternatives discussed in the subject document, each has
drawbacks. Alternatives OD,, OD/RE^ and OD/RE^ as described in the
report would result in the destruction of 3.5 to 5.5 acres of freshwater
coastal marsh (Nearys Lagoon). Nearys Lagoon is a 21-acre freshwater
marsh used intensively by wildlife (over 100 avian species). There is
apparently insufficient upland adjacent to the existing Santa Cruz
Wastewater Facility to accommodate the necessary expansion. According
to the document (p. 303), vacant (though not contiguous) Southern Pacific
property exists on which the secondary treatment facilities could be
located. Even if the project at Nearys Lagoon can be located coirpletely
out of the wetland areas, we are still concerned that continued growth
beyond the 1999 design capacity would eventually require additional
space and that the only undeveloped lands would be the wetlands of
26
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2
Nearys Lagoon. We believe alternatives OD^, OD/RE,- and OD/RE^ would
only postpone the destruction of Nearys Lagoon wetlands and for that
reason recommend construction of a new facility at the "westside"
location, alternative 0D^B with modifications.
Alternative 0D^B calls for construction of new wasterwater treat-
ment facilities west of the City of Santa Cruz. Vfetlands would not
be affected, and sufficient undeveloped upland could be acquired to
accommodate future expansion. However, the effluent would be dis-
charged to the ocean. We believe all possible efforts should be
taken to encourage the reuse of this freshwater source. On the basis
of fish and wildlife values, an alternative (not considered in the
report) which incorporates facility siting at the west side uplands
and the reuse provisions of alternatives OD/RE^ or OD/RE^ would be
a preferred alternative. Hie impacts on the riparian zones through
which the distribution pipelines would cross (Arana Gulch, Schwanns
Lagoon, Rodeo Creek ar*2 Soquel Creek) could be minimized by (1)
construction during the dry season, (2) limiting the size of the
corridor and (3) extensive replanting within the disturbed riparian
zone. A Department of the Army Rsnnit will be required for work
conducted in the stream channels. The Fish arrf Wildlife Service
believes the fish and wildlife resources can be satisfactorily
protected through permit conditions and intends to respond to the
Corps of Engineers on this matter should this project option be
selected.
It is our understanding that the City of Santa Cruz is presently
seeking a waiver as provided for under Section 301H of the Clean
Water Act that, if granted, would allow them to discharge effluent
receiving primary instead of secondary treatment (alternative NP^).
The Act requires that all municipal wastewater treatment facilities
incorporate best practicable waste treatment technology (BPWIT) by
1983. Alternative NP2 is similar to NP^, except that the discharge
would be through an extended outfall.
We are strongly opposed to the granting of any waiver which would
result in less stringent discharge requirements. The objective of
the Clean Water Act as stated in Section 101(a) is . .to restore
and maintain the chemical, physical, and biological integrity of the
Nation's waters" (emphasis added). Hie Act further states that it
is the national goal that the discharge of pollutants into the navigable
waters be eliminated by 1985.
The issue of dilution versus additional treatment continues to be
of concern. According to the subject document, acceptable levels
of toxic constituents, including heavy metals, as defined under
27
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3
the State Ocean Plan would be provided by dilutions between 150:1 to
600:1 (page 319). It is our position that pollutants should be removed
and not simply discharged through longer diffusers into deeper waters.
We believe the dilution approach was considered undesirable by the
authors of the Act and as a result the termination of the discharge
of pollutants was adocpted as the 1985 goal.
In summary, we strongly recommend that the selected management plan
include (1) wastewater reuse, (2) a site location which would not
adversely impact wetlands (present or future), (3) at least secondary
wastewater treatment, and (4) a design approach predicated on pollutant
removal instead of pollutant dilution.
Specific Comments
Page 19, Water Quality. The environmental statement would be
strengthened by including more specific information on implementation
by local farmers of pretreatment of agricultural runoff.
Pages 19-21, Summary. Hie summary table of possible impact mitigation
measures does not include monitoring effects of land application of
wastewater. It appears that at least until the pattern of long-term
effects is established, monitoring unconfined ground water below areas
of land application would be advisable.
Page 240, Alternative OD/RE^. The statement does not evaluate the
probability of adverse effects frcra the proposed injection-extraction
alternative; instead it proposes a pilot study (pp. 19, 240). The
meaning of the term "pilot study" is not made clear. It seems evident
that an initial theoretical analysis of the entire proposed injection-
extraction system will be necessary, both in assessing the potential for
impacts on groundwater resources and in planning pilot field studies
and/or the system design. Results of the preliminary theoretical
analysis should be included in the final statement to permit meaningful
assessment of effects on groundwater.
Page 453, Groundwater. The definition of groundwater seems incomplete
for the term as used in the draft statement. As written, the definition
can be applied to soil moisture and moisture in the zone of aeration or
unsaturated zone. We suggest that the definition given in the glossary
be made more exact by specifying that groundwater is subsurface water
in the zone of saturation.
28
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4
9. Finally, we would suggest that recreation/open space opportunities be
considered in more detail in the plan implementation stage.
If you have any questions on our comments, please contact me.
Sincerely,
Patricia Sanderson Port
Regional Envirormerital Officer
cc: Director, OEPR (w/copy incoming)
Director, Fish and Wildlife Service
Director, Heritage Conservation & Recreation Service
Director, National Park Service
Director, Geological Survey
Director, Bureau of Mines
Commissioner, Bureau of Reclamation
Reg. Dir., PWS
Reg. Dir., HCRS
Reg. Dir., NPS
Reg. Dir., GS
Reg. Dir., BM
Reg. Dir., BR
29
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U. S. Department of the Interior, Office of the Secretary
1. The only wetland that would be adversely affected by
alternatives being actively pursued by the City of
Santa Cruz is Nearys Lagoon. If the city's application
for modification of secondary treatment is not successful,
2-3 acres of wetland might be lost to plant expansion
(facilities needed through 1999). As indicated in the
Draft EIS/EIR and further discussed in this Final (page 176) .
the loss would require mitigation. The "dilution vs.
pollutant removal" and "wastewater reuse" issues are
discussed in following responses.
2. It is agreed that each of the proposed alternatives has
certain environmental (including economic) drawbacks.
One of the primary functions of the EIS/EIR process is
to identify and weigh the environmental consequences
of various alternatives and propose appropriate mitiga-
tions. If an alternative that would adversely affect
Nearys Lagoon wetland is eventually implemented, mitiga-
tion of the damage would be required. This might include
establishment of wetland with equal value. Subsequent
treatment plant expansions would undoubtedly require
similar mitigation because existing wetland protection
policies will no doubt still be in effect.
No final decision on the most appropriate wastewater
facilities modifications has been made, as the planning
process has not been completed as of this writing and
action on Santa Cruz's application for modification of
secondary treatment has not been taken. Therefore,
Alternative OD43 has not been completely eliminated.
However, use of the West site and pursuit of the reclama-
tion opportunities of Alternatives OD/RE5 and OD/RE7
is not likely. The West site is located in the opposite
direction from the OD/RE5 and OD/RE7 reclamation areas?
this would result in construction and operation and
maintenance costs well in excess of those predicted
for OD/RE5 and OD/RE7 with only marginal (if any)
environmental advantages.
3. In September 1979, Santa Cruz submitted an application
for modification of the secondary treatment requirement
under Section 301(h) of the Clean Water Act. Section 301(h)
was added to the 1977 revisions to the Federal Water
Pollution Control Act. No action has been taken on this
application, but the administrator of EPA must consider
the water quality objectives and pollutant clean—up
timetable of the Clean Water Act in making a decision
on the application.
PUj"!"i
-------
4. The issue of pollutant removal versus pollutant dilution
has been given serious consideration in preparing
California's revised Ocean Plan and Santa Cruz's NPDES
permit requirements. These regulations identify dilution
as an acceptable means of protecting water quality and
marine life in the vicinity of wastewater outfalls. The
selected alternative, 0D1a» will provide secondary treat-
ment prior to the discharge of effluent to the ocean.
5. Specific measures for pretreating agricultural runoff
are being developed as part of water quality management
programs funded under Section 208 of the Clean Water Act.
The 208 planning agency in the Monterey-Santa Cruz County
area is AMBAG. Any wastewater reuse scheme including
agricultural irrigation would have to include pretreatment
mitigations developed in the 208 studies. The Central
Coastal Regional Water Quality Control Board would also
provide pretreatment requirements for a wastewater
irrigation scheme.
6. It is agreed that groundwater monitoring should be
required at any agricultural wastewater reuse site.
However, the City of Santa Cruz is not presently
pursuing an agricultural reuse alternative.
7. An initial theoretical analysis of the injection system
proposal was conducted by Brown and Caldwell, the
facilities plan engineers. It was their opinion, after
completion of the initial analysis, that there was
insufficient geohydrologic information on the Pajaro
River groundwater basin to accurately predict the
effectiveness of an injection-extraction system.
Therefore, they recommended that before planning an
injection system, a pilot study to collect more data
on subsurface conditions along the coastal section of
the Pajaro Valley should be conducted. The pilot study
would include construction and monitoring of test wells,
aquifer testing and analysis, and computer simulation
of the proposed injection-extraction process (Brown and
Caldwell, 1978c, pages 10-13). However, this alterna-
tive has not been selected to be part of this project,
so these possible impacts will not take place.
8. The "groundwater" definition in the Draft EIS/EIR should
be expanded to indicate that the term, as used in the
EIS/EIR, refers primarily to subsurface water stored in
the zone of saturation.
9. No response required.
31
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Rcrr |\/np
August 10, 1979
y 1979
Uivisjct. cif if.A.L,. .
Mr. Ed Dito, Acting Chief
Grants Administration Section
Division of Water Quality
State Water Resources Control Board
P. 0. Box 100
Sacramento, California 95801
Re: MCH Number 077931 - Wastewater Facilities Plan
Dear Mr. Dito:
The Association of Monterey Bay Area Governments areawide
Clearinghouse has circulated notice of the referenced State
Plan to our member agencies and interested parties for
review and comment.
The AMBAG Board of Directors considered this Plan on
August 8 and forwards the attached comments for your
consideration.
Px„ase inform us of how you utilize these comments in the
further development of the plan.
Thank you for your cooperation.
Sincerely,
Warren C. Freeman
Regional Planner
Areawide Clearinghouse
WCF/ea
Encl.
32
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comkekis C'OiP^
077925 EIR LOMPICO COUNTY WATER DISTRICT
Regional Water Quality Control Board—Central Coast Region
We have requested a copy of the EIR from the Santa Cruz Planning Department.
We will comment, as appropriate, after we have received and reviewed the EIR..
077928 DEIR PASATIEMP0/R0LLINGW00DS WASTEWATER MANAGEMENT ALTERNATIVE PLAN
Regional Water Quality Control Board—Central Coast Region
Overall, the report appears to adequately address impacts on water quality
associated with the proposed alternatives. We encourage implementation of those
mitigation measures to control soil erosion from possible construction activi-
ties. Where appropriate erosion control measures are taken, Waste Discharge
Requirements are generally not required by this Board. We recommend enforcement
of erosion control by Santa Cruz County.
To reiterate our comments on the project report, we recommend implementation of
one of the three -regional management alternatives. Either alternative to trans-
port Taw wastewater to Santa Cruz or Scotts Valley for treatment would be
acceptable. Construction of a treatment facility with wastewater disposal in the
Santa Cruz outfall, although acceptable, should be considered as the .third choice.
The Basin Plan recommends minimizing individual treatment systems as much as
possible therefore construction of a new system should be avoided.
077931 TREATMENT PLANT IMPROVEMENTS AND DESIGN OF OCEAN OUTFALL TOR "THE CIT?
OF SANTA CRUZ
Regional Water Quality Control Board—Central Coast Region
We are currently reviewing the £ra±t report tor this -proposed project. Oat
comments -will "be forwarded Co the state clearinghouse with a copy sent Zv you.
33
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Association of Monterey Bay Area Governments
No response required, as no comments were forwarded
subsequent to the August 10, 1979 letter.
34
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California Archaeological Site Survey
ARCHAEOLOGICAL REGIONAL RESEARCH CENTER
CABRILLO COLLEGE, 6500 SOQUEL DR.,
APTOS, CA 95003 (408) 425-6294
June 29, 1979
IM MANCltCO
f All MATKO
5 4) 2
Regional
Office
Central
Coast
Paul de Falco Jr.
Regional Administrator
E.P.A.
Region IX
215 Fremont Street
San Francisco, CA
Dear Mr. De Falco:
l-i It is the opinion of this office based on the attached staff review , that
the Cultural Resource section is inadequate by State (C.E.Q.A.) and Federal (N.E.P.A.)
Standards as well as by current archaeological standards (SOPA) to which the archaeo-
logical consultant professes to agree.
It is the understanding of this office that all of the problem areas were identi-
fied and communicated to E.P.A., County of Santa Cruz Sanitation District and the con-
sultant in April of 1978 in hopes th<2 problems could be addressed prior to the EIR.
Our staff review indicates this has not been done. We feel the questions raised by
Ms. Holmes in her review of June 1979 (attached), and those raised by Mr. Edwards in
his role as Archaeological Advisor to the Santa Cruz County Planning Department, should
be addressed in this EIR.
Sincerely,
Regional Office Manager
SK:pn
cc: Porath
Fieberling
Ohlone Indian Cultural Association - Marquez
Society of Professional Archaeologists - Davis
State Office of Historic Preservation - Mellon
Society for California Archaeological - James
Interagency Archaeological Service - Gordon
35
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cHE-IS4-) 2
A Review of the Archaeologies L Element
of the Santa Cruz Areowide
Wastewater Facili tics Plan Draft Elb/(.it<
Ann Peak
i11A - 9 - C A-SjiiUi C i i.i x - VvVv'i
by
Louise iio Lines
State of California ArchaeoJogica 1 Site Record Of u
Regional 01fice
C a b r i. 11 o C o 11 e g o
June 1. D 7 9
ItiTRODUCT ION :
This is a review of the archaeological portion of a Ura ft Envn'on-
inental impact Statement and Envitonmental Impact Repot": which '-.as
been done for the Santa Cruz Regional Wastewater System. .it is
more specifically an attempt to determine if the quality of the
archaeological discussion had undergone any improvement from the
original archaeological report Ms. Pe«ik die! for the project (12/1-/77)
after the Archaeological Advisor of the Santa Cruz Planni.no Depart-
ment, Mr. Rob Edwards, wrote a rather scathing review (4/27/7B) out-
lining ail of the deficiencies in the original report. Dr. Robert
Carticr commented at that time on the deficiencies of Ms. Teak's
original archaeological report, also. Both reviews were done using
the standards of the Society
orqanization whose standards
of Professional Archaooloo
are widely accepted.
/ i
a national
1. The following areas of the Code of Ethics appear not have been ad-
hered to in Ms. Peak's original report, according to Mr. Edwards and
Dr. Cartier :
1.1.1c - Be sensitive to, and respect the legitimate concerns
of groups whose culture histories are the subjects
of archaeological investigations.
An archaeologist shall not;
opi n i.on , make
1.1.2b -
Give
a public report, or
a professional,
give legal tent" i ~
mony involving archaeological matters without. b'!ing
as thoroughly informed as might reasonably 1
wO
:
-------
In the area of Standards of Research Performance, the report does
not indicate that the following SOPA requirements were met:
1.1.2. - Inform himself/herself of relevent previous research.
1.1.3 - Develop a scientific plan of research which specifies
the objectives of the project, takes into account pre-
vious relevent research, employs a suitable methodology
and provides for economical use of the resource base
(whether such base consists of an excavation site or
of specimens), consistent with the objectives of the
project.
III.3.2. - Uncollected entities such as environmental or cul-
tural features, depositional strata, and the like,
must be fully and accurately recorded by appropriate
means, and their location recorded.
III. 3.3 - The methods employed in data collection must be fully
and accurately described. Significant stratigraphic
and/or associated relationships among artifacts, other
specimens, and cultural and environmental features
must also be fully and accurately recorded.
Following is a summary of the deficiencies in Peak's original report
as applied against the above SOPA standards, along with an analysis
of the improvements, if any, in the draft EIS/EIR.
SOPA ETHICS - I.1.1c
The "groups whose culture histories arc the subjects of archaeological
investigations" in this case are Native Americans. Ms Pea did not
indicate in her first report whether the local Watsonville Native
Americans had been contacted. The draft EIR/EIR indicates no change.
In addition, in her original report, her recommendation that a Native
American observer be on an as-need basis" was deemed inadequate m ^
light of the current practice of insuring that the local native People s
bo included early in the planning process. The draft EIS/EIR fortu-
nately contains minor improvements in this area. On page 30 , sne
states that if Alternative 0D4B is chosen, since the surface survey
found a significant amount of broken shell, indicating the potential
for a buried site, "a Native American observer would be part of the
excavation crew." If Alternative 0D/RE5 is chosen, since three known
recorded sites (SCR-138, SCR-171, SCR-172) lie in the area of direct
impact, she recommehds (page 314) "if excavations are necessary (at
SCR-138), a Native American observer should be obtained to monitor the
work. Construction activity in the vicinity of JS-SWT-1 and JS-SWT-2
should also be monitored by a qualified archaeologist and a Native
American." Oh pages 317 and 318, her discussion of Alternative OD/RE7
mehLions that since three recorded sites (SCR-101,. SCR-102, cind MN1-226)
and two potential sites, "c" and "d"", lie in the area of direct impact.
Therefore, if test excavations are done, "a Native American observer
should be on call in case significant cultural resources are unearthed.
37
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This last points out the inconsistencies in her recommendations.
The recommendation that a Native American observer be required in
the first two cases was absolutely correct. However, the Native
American should also have been required in the case of 0D/RE7,
rather than "on call", as Ms. Peak suggests. Further, on page 315,
she says that for Alternative 0D/RE5, recorded site MNT-500 lies
in the line of direct impact so test pits should be excavated to
determine if cultural material does exist there. But she does not
mention that a Native American observer should be required. Her
recommendation in the case of Alternative 0D1 was inadequate as
well. No evidence of a site was discovered in the survey of the
impact area, and the potential for any uncovered during excavation
is low because the area of Neary's Lagoon was and still is, a wet-
land. She recommends that "if significant amounts of shell and
bone are unearthed during construction, work should be halted and
a qualified archaeologist should be consulted..." (page 304). No-
where' does she mention that, in this event, a Native American ob-
server shoudl be called in as well. This is an especially serious
omission, since Project Alternative OD1 has been selected for im-
plementation .
SOPA ETHICS - I.1.2b (Responsibility to Public) and
II.2.lb (Responsibility to Colleague)
The original objection that Ms. Peak's report showed no evidence of
recent, regional and arhcaeological research being utilized, still
stands.
SOPA STANDARDS SECTIONS:
Mr. Edwards and Dr. Cartier objected to the original report because
its discussion of ethnographic archaeological and historical research
was too general, relying on only the most general of sources when
there are may sources available which provide information specific
to the local cultural groups; her references did not include the
work of other archaeologists in the area or the site reports of sites
mentioned. In general, her report was found to be "grossly lacking
in archival data" (Cartier) and "lacking in awareness of relevent
local and regional data, problems, models, and theoretical basis for
the use of the data" (Edwards)-
This section of tho EIR/EIS remains grossly inadequate. The sources
recommended by Edwards were totally ignored. The report in this res-
pect is identical except that the historical background section has
been condensed, a discussion pf the potential for underwater cultural
resources (emphasis on sunken ships) has been added (pp. 113, 115-116,
119) and a list ot the historic sites in Santa Cruz County which are
included in the National Register for Historic Places, has been added,
(pi»go 120) . Again, neither of these additions is relevent to the
question of whether any of the prosed alternatives for the Santa Cruz
as ewater Treatment Facility will have any impact on existing cul-
ura resources. The discussion of submei-ged cultural resources is
too general. None of the sites listed in the National Register of
Historic Places lies anywhere near any of the proposed project alter-
natives.
38
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Further objections to Ms. Peak's original report have not been
changed in the draft EIS/EIR. They include the following problems
with her methodology:
a) site limits were not identified and no site specific
data submitted (page 117).
b) the description of survey methods does not specify
which areas were surveyed by car and which by foot.
c) no subsurface testing or surveying was done "in areas
of buildup or where streets cover the ground" (page 116)
This is in reference especially to the area of the chosen project
alternative (0D1J, Neary's Lagoon. Since cultural resources have
been found in areas surrounding Neary's Lagoon, the area should
have been surveyed by Ms. Peak.
d) she developed no strategy of research
In summary, the archaeological portions of this draft EIS/EIR re-
port are too general and could have been done without ever having
done any background research in the area, as Mr. Edwards pointed out
in reference to the original report. The actual report submitted
by Ms. Peak is included in the draft EIS/EIR as Appendix B, and is
word for word identical to the original report whe wrote. However,
the body of the draft EIS/EIR does contain some minor changes. No-
where in the report does it say where the new information came from.
A letter of revision should have been incorporated into the draft
EIS/EIR, as well.
The minor changes she implemented include:
a) she specified the requirement that a Native American
observer be present for any excavation activity (though
her recommendations in this area were inconsistent).
b) she specified the need for the presence of a qualified
archaeologist during construction activity at potential
cultural sites.
c) she made mitigation recommendations specific to the
fcur project alternatives, recommending either that
proposed construction sites be moved (pp. 314, 317),
or that t&st excavations be made - in the presence of
Native American observers (pp. 309, 314, 315, 317), or
that construction activities be halted and a qualified
archaeologist be called in if cultural materials were
uncovered (although in this case she neglected to mention
the need to call in a Native American observer, as well).
These changes are minor. The most serious problems with the archaeo
ogical discussion remain. The report is lacking in archival, ethno
graphic specific references. It is too general by far in its dis-
cussion of the regional archaeological background. It still is
oer.ously lacking in evidence of familiarity with local regional
research questions and problems, archaeology, and previous research.
39
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The methodology employed leaves much to be desired. By current
professional standards, the archaeological segment is grossly in-
adequate.
In light of the fact that Project Alternative 0D1 has been selected,
Ms. Peak's recommendations are inadequate. She made a recommendation
of No Adverse Effect (in so many words anyway) for construction activi-
ties .in the Neary's Lagoon area. This constitutes an irresponsible
decision by an archaeologist in view of the known proximity of the
area to other prehistoric sites and considering that she did not
even completely survey the area (pp. 116-117).
40
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2
A REVIEW OF- ARCHAEOLOGICAL 'ELEMENT
OF THE SANTA CRUZ REGIONAL
WASTEWATER TREATMENT SYSTEM PROJECT REPORT
by Ann Peak
ENVIRONMENTAL MANUSCRIPT E-4S-MNT
by
Rob Edwards
Archaeological Advisor
Santa Cruz County Planning Department
INTRODUCTION
This is a rev'cw of an archaeological portion of an environmental document that
is being done as ,n [R for the Santa Cruz Regional Wastewater System. As the
Archau0l09ie.il Advisor to the Santa Cruz County Planning Department, I would normally
review this report at the time the draft EIR was filed. However, upon receiving the
report at the Regional Office, I was sufficiently dismayed that I decided to review
the report at: this time and sought a second opinion on the adequacies of the report.
(Dr. Robert Cartier - report in Appendix). I have informed Ms4. Peak that this review
is in process, in hoses that the problems in the report can be'corrected prior to the
filing of the draft EIR.
In reviewing this report, both Dr. Cartier and I have used the standards of the
Society of Professional Archaeology (SOPA), a national organization t.o which Ms. Peak
has applied for membership and whose standards are widely accepted.
"Membership in SOPA is open to all applicants who meet the quali-
fications and who subscribe to the Code of Ethics and the Standards.
£0PA, 1977). See Appendix A.
I have listed the ethical and research issues that are in question, and
discuss each in detail in the following section. The SOPA Ethics and Standards are
1 isted in Appendix B.
She following areas of the Code of Ethics appear not tohave been adhered to in
the report.
I,l.lc - Be sensitive to, and respect the legitimate concerns of groups whose
culture histories are the subjects of archaeological investigations.
I»1,2b •• An arehaec'iogist shall not: Give a professional opinion, make a
public rppyf't, or give Tc-gal testimony involving archaeological matter;
Without beititj as thoroughly informed as mioht reasonably be expected.
II,2.lb - Keep informed and knowledgeable about developments in his/her field or
fields of specialization.
41
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In the area of Standards of Research Performance, the report does not indicate
that the following SOPA requirements were met: .
1.1.2 - Inform himself/herself of relevant previous research.
1.1.3 - Develop a scientific plan of research which specifies the objectives
of the project, takes into account previous relevant research,
employs a suitable methodology, and provides for"economical use of
the resource base (whether such base consists of on excavation site
or of specimens), consistent with the objectives of the project.
111,3.3 - The methods employed in data collection must be fully and accurately
described. Significant stratigraphic and/or associated relationships
among artifacts, other specimens, and cultural and environmental
features must also be fully and accurately recorded.
SOPA ETHICS - I,1.1(b) "Responsibility to Public" states the need for archaeo-
logist to "be sensitive to"...groups whose culture histories are the subjects of
'archaeological investigation. Ms. Peak does not indicate in her report any contact
with the local Native Americans, who live in Watsonville, approximately three miles
from the project area. In addition, her last sentence recommending "a Native American
observer be on an as-need basis" is not consistent with, current archaeological
practice in this area which includes•contacting the local native peoples early in the
planning process.
In 1.2(b) (Responsibility to Public) and in 2.1(b) (Responsibility to Colleague)
the ethics require the archaeologist to be "as thoroughly informed as might reasonably
be expected" and "Keep informed and knowledgeable about developments in his/her
field." Vnis issue is best discussed within the context of Standards, but is, in
fact, ttw i:
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f mainly contains general ized statements such as:
"The plant foods utilized by.the Cnastorfoans were the usual ones
utilized by California Indians."
This is a totally non-informative statement to a) the lay reader, b) the bureaucrat,
or c) the archaeological professional.
The hoyton,ic.al fie.6ta.ich while better than the other sections, again shows a very
superficial level of research (published sources available in a public library) arid
no attempt tc utilize local or archival historical data in identifying local resources
in the project area. One example of this is a discussion of the killing of Father
Quintana by local peoples. Interesting, but no attempt was made to relate the killing
to a site which might have been on the original project line. Again, archival data
and manuscripts exist that could have been used to look at the project area specifically
concerning historical resources. Stich archives include: Santa Cruz City and County
Museums, Pajaro Valley Historical Association Archives, UCSC Regional Historical
Archives, UCSC Maps Library. There are recent publications' on the area in local
periodicals and again manuscripts.of previous research done by professional archaeo-
logists and historians on the project area. Easily available examples specifically
relevant to Peak's report area are: ARS, Live Oak Plan; ARS, Aptos Sewer Project;
Lydon, Soquel Landing to Capitola-by-the Sea; Edwards & Farley, Pajaro Valley Report.
Regionalized repc*s~ that illustrate theoretical applications and model building for
the area are: King u Hickman San Fel ipe; Fritz (et. al.) Proposed Rolling Woods/Scotts
Vallev Wastewater Project; ARS, Scotts Valley General Plan..
The ^ichacoloiuaai' tr.snatch section is truly locking in awareness cf relevant
local and regional'data, probjeras, models and theoretical basis for use of the data.
There is absolutely no references to any relevant local archaeological investigation.
Missed was a report on an excavation previously completed on one of the sites discussed
in the report! (ACRS, Pajaro Headlands Report, 1976}
There is no statement of a research strategy as required by SGPA Standards 1,1.3.
There is no indication of concern"for theoretical models or problems to be tested from
other archaeological researchers (e.g. King, C. & L., General Research Design).
«»,
Methodology is poorly described and does not seem to meet SOPA Standards 111,3.3.
Peak or. page 10 states, .sites...previously recorded...were carefully examined to
relocate and assess the sites." However, no site record forms were filled out to up-
(:ate =r.^hival records. New sites were poorly recorded and site limits were net
identified. On page 11 and 12, areas of shell that ".cannot be disregarded" are dis-
cussec! but no site specific data was submitted.
Areas surveyed are casually described as was the'method of survey. (No indicatic-n
of which areas are surveyed by car, which by foot, etc. Page 9). Areas where actual
survey occur (open land or vacant land) need to be identified so evaluation of the
level of actual area covered can be determined, and mapped.
No attempt to, survey or subsurface test were made in areas of buildup or whore
streets cover the ground. This is highly unusual given the occurrence of valid cultural
tesourccs in this area, a possibility the author acknowledges on page 12. best recent
example would be Pacific Grove - Monterey Sewer Line Project, "ACRS in process." The
old Sacramento project is another example. ~
43
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The concluUor.i section on paga 12 is so general it could have boon written
withcut ever doing any background research specific to the area. Again, no attempt
was made to gather specific data in ethnography, history or archaeology (besick.-s
site record reports), and no attempt was made to use this data to predict specific
site locations.
The "sensitive zone" recommended on page 13 is an unusual recommendation for a
project specific survey as this one is supposed to be. The areas should be tested
to determine their significance and provide CCQA - NEPA levels of data.
The lack of local research shows on page 11 and page 10 where the discussion of
SCr-10! does not include the test excavation carried out by ACR5 - Pajaro Headlands
on that site.
In summary, the Report does not seem to meet the minimal standards of the
Society of Professional Archaeologists. It is seriously inadequate in the six areas
listed on pages 1 and 2.
I would ecru<11,y have to recotnmpnd to the County of Santa Cruz that this report
is unacceptable as currently written.
44
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Moratto, Michael J.
Roop, William
Roop, W. & Flynn, K.
Edwards, R. & Farley, M. R.
King, Chester
Roop, W. & Flynn, F.
Lydon, S. S Swift, C.
Fritz, et. al.
ACRS
Kino, C. 0. & Linda King
AnthropoToqicnl and Ethnohistorical Sources for_t ho
San Francfsco ba.y~~Req~ion. San Francisco State'" University,
Treganza Anthropological Museum Papers #13. March 1974.
Adaptation on Ben Lomond Mountain*. Excavatiqns at
4-SCr-20. Masters Thesis. San Francisco State College.
May 1976.
(ARS) Archaeological Impact Evaluation - Aptos County
Sanitation District Proposed Pipeline Evaluation. Santa
Cruz County Wastewater Agency. January 1975.
An Assessment of the Cultural Resources of the Lower
Pajaro River Basin, California, with Selected Preliminary
Field Study. Corps of Engineers. August 1974.
Calendarruc Ethnohistory in Edwards & Farley. An Assessment
of the Cultural Resources of the Lower Pajaro River Basin,
California. Appendix 1. August 1974.
(ARS) Live Oak General Plan. Cultural Resource Element
for Santa Cruz County 1977.
Soquel Landing to Capitola-by-the-Sea. California History
Center. DeAnza College. Local History Studies - Volume 22.
1978.
Archaeological and Historical Reconnaissance of Areas to
be Impacted by Proposed Rolling Woods/Scotts Valley
Wastewater Project. April 1975.
Archaeological Test Excavations and Impact Evaluations,
Pajaro Headlands, Santa Cruz County. For Santa Cruz
County, 1975.
General Research Design. Bay Area Archaeological Coopera-
tive. In T. F. King and Pat Hickman, The Southern Santa
Clara Valley: A General Plan for Archaeology. N.P.S.
manuscript. 1973.
45
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California Archeological Site Survey - Archeological Regional
Research Center
1. The concerns expressed in this letter appear to reiterate
those submitted earlier by Mr. Rob Edwards of Cabrillo
College in relation to the original project archeological
report prepared by Ann S. Peak and Associates (Mr. Edwards'
letter follows that of the California Archeological Site
Survey). To reiterate an earlier letter of response
to Mr. Edwards, EPA is not responsible for enforcement
of the Society of Professional Archeologists (SOPA)
Code of Ethics. EPA is responsible for assuring that
projects funded under Section 201 of the Clean Water
Act comply with all applicable federal and state regula-
tions, including NEPA, CEQA, and the National Historic
Preservation Act. It is not the intent of NEPA and CEQA
that environmental documents be the product of exhaustive
research projects; they are intended to disclose and
describe all potentially significant environmental impacts
of proposed actions.
It is the opinion of EPA that the archeological and
historical analysis prepared for the Santa Cruz facilities
plan EIS/EIR adequately disclosed potential impacts as
required by federal environmental and historic preservation
laws and regulations. The project currently being considered
by the City of Santa Cruz would not impact sites designated
or potentially eligible for inclusion on the National
Register of Historic Places. No recorded or previously
undiscovered archeological sites were found in the primary
area of impact. Adequate recommendations were made for
protection of cultural resources should they be uncovered
during facilities construction.
2. A native American observer will be employed to monitor
any project excavation at or near identified archeologic
sites, regardless of where they are located. This includes
excavation in Nearys Lagoon.
3. The major role of the archeological survey and report
prepared for Santa Cruz was to identify and suggest
mitigation for any adverse impacts to known or as yet
undiscovered cultural resources should a project be imple-
mented. Emphasis is not placed on describing the ethno-
graphic and historic background of the study area. It
is felt that the appropriate sources of site data (State
Office of Historic Preservation, regional site survey
center at Cabrillo College, National Register of Historic
Places, California Historic Landmarks) were utilized
and that the impact discussions adequately address the
potential for loss or damage of cultural resources should
the proposed facilities plan modifications be undertaken.
46
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4. As stated on pages 116 and 117 of the Draft EIS/EIR,
all proposed facilities sites on open ground were
surveyed by foot except for a small section of the
pipeline route for OD/RE5, where access to private
property could not be obtained. (Alternative OD/RE5
is not being pursued by the city.) All urbanized sites
were surveyed by car; this refers to pipeline routes
that were to be located along paved roads.
Subsurface testing and determination of site boundaries
is not undertaken until a project is finally selected
from among the alternatives. This avoids excavation
in areas that will not be affected by project construction.
5. Revisions to the original report were made by Jones &
Stokes Associates staff in cooperation with Ann S. Peak
and Associates. These revisions were not made in the
original archeological report, they were simply incor-
porated into the text of the Draft EIS/EIR impact sections.
47
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STATE OF CALIFORNIA
EDMUND G. BROWN JR., Co.emc
CALIFORNIA COASTAL COMMISSION
CENTRAL COASTAL REGIONAL COMMISSION
701 OCEAN STREET, ROOM 310
SANTA CRUZ, CALIFORNIA 9J060
(-408) 426-7390
September 7, 1979
State Clearinghouse
Office of Planning and Research
1400 10th' Street
Sacramento, CA. 95801
State Water Resources Control Board
P.O. Box 100
Sacramento, CA. 95801
Environmental Protection Agency
Attn: Hearing Office, HE-154
Region IX
215 Fremont Street
San Francisco, CA. 94105
Subject: Draft Environmental Impact Statement and Report
Santa Cruz Wastewater Facilities Plan, May 1979
State Clearinghouse Number 79070310 P
Public Review period extended by EPA until September 12
Dear Project Evaluators,
The following composes the Central Coast Regional Corrmission Staff comments
on the draft EIS/EIR for the Santa Cruz Wastewater Facilities Project. Under
the California Coastal Act of 1976 (especially Chapter 3), the Coastal Corrmission
has broad responsibilities for the protection of the resources of the coastal
zone.
We have organized the staff comments on the EIS/EIR by first listing general
comments on the entire document followed by more specific comments organized by
subjects and a group of miscellaneous comments.
General Comments
In our staff review of the Draft EIS we found the document to be voluminous and
often quite redundant and difficult to follow. The document does contain a
substantial amount of sound technical information, as well as much out of date
information. There are many assumptions and statements that are made that are
not clearly supported by analysis or reputable references. There has been a
substantial amount of work done by the consulting engineers and oceanographic
consultants as a part of the overall facilities planning study. Because of the
large number and the length of the documents produced as a part of the facilities
plan it is important that the EIR/EIS clearly state by document name and page
number the work that supports statements made in the EIS. We note that the
bibliography does list other supporting documents and that they are also mentioned
48
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-in passing in the text, but footnotes and page listings are rare. This makes it
quite difficult for citizens and the agency reviewer with limited time to find
and read the significant background information. Also the oceanographic report
and project report are not widely distributed. The wastewater facilities planning
program will have long range impacts on the environment and people of Santa Cruz
City/County and it is critical that there be a informed citizenry to assist in
the decision making process. The present organization and length of the document
make it difficult for any but the most zealous citizens to be involved in the
process.
In regard to public participation and understanding of the project, Chapter 1 -
The Report Surrmary is the most important section of the entire EIR/EIS. It is the
section that will be read by the majority of people. The surrrrary as now written
does a good job of highlighting many of the major issues raised by the four alter-
native projects considered. However, the summary does need to be updated with more
current information on population figures, the County and City Growth Management
ordinances, the final EPA Regulations on secondary waivers, the controversy over
secondary vs. primary treatment and the changes in air quality regulations. These
needed changes are discussed in more detail later in this letter. The sumrary
should also include footnotes with pages and reference citations to support the
statements made.
We realize that normally the final EH^EIS consists of the original draft
text with responses to comments. Vte feel in this case that a full revision of
the text of the summary is warranted because of the range of unresolved issues
and need to update information.
Attached are six pages of more detailed carments on the subject EII^EIS.
We sill be happy to discuss the ccrments if clarification is necessary. Please
contact Susan Hansch or Nadine Peterson of the Coirmission staff for further
information.
Very truly yours
Edwarja Y. Brown
Executive Director
cc: City of Santa Cruz
County of Santa Cruz
EYB/cw
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LAND USE
1. Acreage of Vacant Lands, Wetlands and Wildlands - Page 143-144
Acreage of land uses in service areas are broken dcwn on Table 3-39. The
land use category for vacant land includes wildlands and ¦wetlands. The
projected acreage of this land use is then obtained by subtracting, the
projected acreage within each of the other land use categories frcm the total
acreage within each service area. This method raises the question of whether
the "wild" or wetlands are being subtracted out for future development. The
Coastal Act contains strong language relevant to the protection of sensitive
habitat areas and coastal waters. Therefore, it would be necessary to break-
down this land-use category and separate out the wildland and wetlands from
the vacant lands in order to determine a more realistic estimation of
developable land.
2. Regional Land Use Planning, California Coastal Coirmission - Page 158
The discussion related to the Coastal Ccmmission does not surrmarize policies
in the Goastal Act which may have an impact of future land use in the coastal
zone. Without going into a great deal of detail it would be appropriate to
mention Coastal Act policies such as: concentration of development, protection
of agricultural lands; protection of sensitive habitat areas; protection of
marine resources; provision of public access to the sea and, encouragement
of visitor serving carmercial recreational uses; along with references to
the relevant sections in the Act. We would be happy to assist you in this
process. In addition, a clarification should be made in the information
regarding the appeal process following the adoption of coastal programs.
Only certain local decisions may be appealed, these decisions are specified
in Section 30603 of the Coastal Act. It would be helpful to site this
section for the readers information.
3. Santa Cruz County's Goals for Future Growth and Land Use - Page 188
As in the section on population projections, this discussion is outdated and
should be revised to reflect the recently established growth management
policies that were formulated as a result of the passage of Measure J.
4. Santa Cruz City' s Goals for Future Land Use - Page 160
The discussion of the City's policies will also need to be updated to reflect
the growth management policies approved by the voters'by passage of Measure O.
5. Projected Land Use Changes - Page 162-169
The projected land uses for each jurisdiction should be reconsidered to
reflect current goals for future growth; revised population figures; and
Coastal Act policies (protection of wetlands, agricultural area, etc.).
Based on the new policies, it may also be necessary to revise and update
the projected number of housing units by service area as laid out in Table
3-47 on page 165.
ECONOMICS
1. Employment Forecast — Page 193
The projected annual employment growth rate is 3.1%. This growth rate sub-
stantially exceeds the projected annual population growth rate (2%). A
discussion on the correlation between population growth and employment is
needed.. According to page 196 of the EIR, the historic expansion
50
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rate of employment was 4% which closely correlated to the population growth
of approximately 4.1%. What are the implications of an employment rate in
excess of the population grcwth?
2. location of Future Employment - Page 196
Hie projected locations for future employment are also based on information
available prior to the passage of the local growth management plans. The
distribution of future employment and related development may be substantially
modified by the new growth management policies and recently adopted urban-
rural boundaries (April 1979). In addition, updated information in AMBAG's
Population and Employment report should be considered in the Final EIR.
POPULATION
1. Population Introduction - Page 120
The introductory paragraph should be expanded to include a discussion of the
relationship of future and present populations in the study and service areas,
to wastewater facilities planning. In other words, hew are the study area
projections used in planning for facilities?
2. Permanent Population - Page 121-122
This discussion along with the formation of table 3-24 implies that Wilder
Ranch and the Secondary Reclamation Areas, are in themselves "service areas"
The distinction between the service areas and the subparts to the planning
areas should be made both in the discussion and in the tables.
3. Report Summary - Page 4
The explanation of use of the gallons per capita per day (gped) increment to
account for non-permanent population in the capacity calculation is weak and
confusing. More explanation is needed to clarify the difference between
planning for a 1989 population (118,040) which does not take into acoount
the non-permanent population, while receiving State funding for a maximum
population of 128,515 but in actuality being able to accomodate an expected
population of 175,520. Why is a gpod incremental flow rate used to account
for non-permanent population? Does the SWRCB's fundable service area
population take non-permanent population into consideration?
/i
4. Report Summary - Figure 1-2
It is difficult to clearly distinguish boundaries of service area sub-units
in relation to other boundaries. In particular, the outside boundaries are
not identified which leaves confusion over whether the Secondary Reclamation
Area is a separate sub-unit service area and whether the upper boundary of
Ctounty Area A extends north to the Scotts Valley area. It would be helpful
to include an additional map which more clearly identifies the areas. In
addition a more detailed map which identifies street boundaries would be
helpful to readers for comparison with other planning areas.
5. UCSC Enrollment - Page 121, Page 138
Projections of future enrollment at the University were based on information
obtained in 1976. Enrollment has sinoe dropped contrary to an anticipated
rise in enrollment and it is currently projected that enrollment will
drop further in the 1980-81 school year. (Source UCSC office of Planning &
Analysis). It would be appropriate to update this information to the greatest
extent possible.
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6. Data Use for Population Projection - Pages 522-551
There are several areas where the data used for projections is scmsvhat con-
fusing, requires clarification or updating. More specifically, the following
subjects raise questions which should be responded to in the Final EIR.
a) Page 519, Headship rates and household heads are used to translate
employment data into population estimates. However, no where in the
document is there a definition of "household heads". Does this relate
to the primary income generator in a household? Does it take into con-
sideration the growing number of households who have two wage earners?
Finally, if income is the primary consideration, how would the 1989 and
1999 projections be affected by the increasing number of households with
two wage earners?
b) Page 520, The 1976 estimated household size is 2.9 persons (for
households with employed household heads). This number is used (along
with an annual rate of decline of .33%) to project future populations.
The Santa Cruz County 1976 Special Census reveals the actual household
size to be 2.56. Why is there such a discrepancy? Is the 2.9 figure
an estimation which is slightly high, or does it also take into con-
sideration of household size in Monterey County? This discrepancy should
be explained and the figures and projections modified if appropriate.
c) Page 538, Vacancy rates are used to forecast the non-permanent
population. According to the EIR, the overall housing vacancy rate in
the county was 12.4 in 1976. This information appears to be contrary
to the 8-10% vacancy rate in the County's "Housing Report - Growth
Management Plan 1978". 2.3% of the units are noted' in the County's
report to be vacant rental and sale units, while the remainder are
unavailable for rent or temporarily off the market. The discrepancies
between these figures should be explored and ccnrmented on and projections
should reflect modified figures, if modifications are appropriate.
7. Population Projections
a) Page 133, According to the report, population was forecast in con-
formance with State Water Resources Control Board facilities planning
guidelines. These guidelines should be referenced for the readers
information.
b) Page 135, For the portion of the study area within Monterey County,
population forecasts were based on the Monterey County Transportation
Study (1973). While this report was considered to be the most accurate
projection available at the time this EIR was prepared, AMBAG has
since released an updated report on population and employment (Pop-
ulation and Employment, April 1979) which takes into consideration
data obtained in the 1976 census. Therefore, it would be appropriate
to revise the population figures to reflect current information.
c) Page 130-142, Projected population growth for the study area and
specific service areas was based on available population data as well
as local policies and regulations governing grcwth. As you are aware,
both the City and County of Santa now have grcwth managsnent provisions
that will have sane impacts on future growth. Because as stated on
page 513 of the EIR, the forecast of residential population is the
most important single input to the wastewater facilities planning
process, it is important that the projections of total population and
distribution of population be revised to reflect changes brought about
by the growth management ordinances.
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OTHER MISCELLANEOUS COMMENTS
1. Status of Santa Cruz Long-toed Salamander - Page 98-102
These pages contain ccmments on known populations of the Stanta Cruz Long-toed
Salamander (SCLTS) which are out of date. There are currently six known habitat
areas containing the SCLTS. These include the two mentioned in the EIR in
addition to populations at the following habitats: Seascape Pond, NfcClusky
Slough, and Bennett/Struve Slcugh and Moro Cojo Slough (Population Study of
the Santa Cruz Long-toed Salamander at Valencia Lagoon 1977-78", California
Department of Fish and Game, Contract #S-1180).
2. Water Quality - North Coast Streams - Page 75
The report states that the only significant water quality problem in the
small coastal streams is sedimentation frcm erosion. To the contrary,
Laguna Creek Watershed has experienced water quality problems resulting
from fecil ooliform. In 1978, a "boil order" was issued by the State
Department of Health to make drinking water safe for consumption by
residents. In addition, the County's Environmental Health Department has
recently stated that every creek in the north coast is polluted and unsafe
for drinking. Therefore, while it may be that most of the streams are
not polluted frcm septic tank effluents, there remain sane water quality
problems. This statement should therefore be re-worded and updated.
3. location and Topography, West Treatment Plant Site- Page 209
This discussion should include a description of the location of Wilder Ranch
State Park and Antonelli's pond in relation to the project site. These sites
should also be identified in figure 4-5 (Land Use Map of the Vicinity of
Project Area) on Page 212.
4. Planning, Regulatory Responsibilities of the California Coastal Commission
Page 253
The discussion of the California Coastal Zone Conservation Commission (OCZCC),
or our predecessor Commission should be replaced by an updated or more detailed
discussion of the California Coastal Commission. As you are aware, the Coastal
Plan was not adopted by the Legislature, rather the California Coastal Act of
1976 was adopted which created the California Coastal Commission (COC) and
six regional Coastal Gamdssicns. The Coastal Plan is no longer in use by
the Commission, but the policies and provisions in the Coastal Act lay out
the foundation for regulating development in the interim permit process as
well as development following certification of the Local Coastal Programs.
In addition, the coastal zone boundary was substantially modified under the
1976 Coastal Act ar>d now runs alon^ Western Drive and in approsunately 5
miles from the ocean west of Western Drive. This information should be
updated in the Final EIR for the project. Additional information on the
boundary or provisions of the Coastal Act may be obtained frcm the Commission
office at 701 Ocean Street, Roan 310, Santa Cruz.
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DISCUSSION OF ALTERNATIVES
1. Report Summary Pages 5 and 6
The summary does not include a clear discussion of the size of the proposed
project under the various alternatives (MGD). This should be included on
pages 5 and 6.
2. Chapter 6 Page 257
As discussed on page 257, PL 92-500 requires discussion of "alternative waste
management techniques". While the report includes a discussion of four alter-
natives they all use conventional treatment techniques. Were any innovative
lower-energy use alternatives analyzed or considered? While it may be diffi-
cult to implement such a proposal for a regional treatment plant on a full
scale, it could be feasible to include a pilot study of seme possible alterna-
tives. There should be some discussion included as to why the westside site
was the only location alternative listed other than the Neary's Lagoon site.
IMPACTS OF ALTERNATIVE PROJECTS
1. Project Summary - Effects on Marine Environment Page 11
This is an example of where statements are made that should be referenced and
supported by other sections in the report or other documents. Example, "few if
any effects on marine biota are expected to be detectable due to high levels of
dilution provided by diffuser design and existing ocean current conditions."
2. Impacts on Ocean Discharge Routes IB, 1C, 3B, 3C, 3X Pages 344,346
One of the concerns of ocean discharge of wastewater is the frequency of
shoreline contact of wastewater. The discussion on page 344 points out that
with the proposed alternatives IB and 1C there would be a higher frequency of
shoreline contact than with alignments 3A, 3B, 3C and 3X. What is the frequency
difference? This discussion should include a reference to the source of this
information. Water quality for the UCSC Coastal Marine Lab, as well as for
adjacent State owned beaches is critical, and the EIR/EIS should include a clear
discussion of the relative difference (quantitative) of shoreline contact and
the typical number of times per year that malfunctions could occur.
3. Secondary Treatment Waiver Project Summary Page 6
This section should be updated to reflect the newly adopted federal regulations
for secondary treatment waivers. A discussion of the applicability to the Santa
Cruz situation should also be included.
4. Air Quality Page 16
This section should be updated to reflect current air quality regulations and
status of local "non attainment" plans. The updated air quality discussion
should be correlated to a discussion of the population projected under the applic-
able grewth management ordinances.
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MITIGATION MEASURES
While the EIS/EIR does a fairly good job of pointing out the major impacts of
the various alternative projects a detailed analysis of feasible mitigation
measures is lacking. Possibly the appropriate location for a summary discus-
sion of the implementation of mitigation measures would be in Chapter 13,
p. 427-428 Significant issues to be resolved.
Before the EIS/EIR is certified as final, strong mitigation measures must
be made an integral part of the selected project. The EII^EIS should not
be certified until a project can be selected that is consistent with all
federal, state;and local water quality and planning regulations. These
should include:
- detailed implementation program for all impacts to Nearys Lagoon
(i.e. wetland - marsh restoration program (Sections 30231 and 30233)
of the Coastal Act establish strong policies for the preservation of
wetlands). Any mitigation program would have to be evaluated against
these policies.
- Water conservation program to partially mitigate for increased water
usage and lack of reclamation scheme.
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California Coastal Commission - Central Coastal Regional
Commission
1. EPA recognizes that the Draft EIS/EIR was voluminous and
that some material had become dated by the time of
publication. These problems are due in part to the
fact that the planning process has spanned nearly
4 years to date. Many of the data collection tasks,
both for the EIS/EIR and the facilities plan, were
undertaken in 1976. Efforts to update data were made
periodically, but were restricted to what appeared to
be the most important topics. The lengthiness of the
report is due to the large number of project alternatives
carried through the planning process and to the large
number of environmental issues raised by the diversity
of alternatives.
The project's engineering reports, including facilities
plan and oceanographic study, were used extensively
for EIS/EIR data. While each statement and assumption
is not specifically referenced to a certain page, the
source document is usually mentioned. These engineering
reports have been put on file at the U. C. Santa Cruz
and Santa Cruz Central Libraries and at the City and
County Departments of Public Works. Review of all of
these documents is obviously a major undertaking; it
is hoped that by using report titles and tables of
contents, persons can locate specific topics of interest.
2. Updated discussions of the various significant environ-
mental issues are presented in several sections of this
Final EIS/EIR. Chapter 2 (pages 5-17) and the last
major section of Chapter 3 (pages 170-192) provide
much of this update, but responses to comments in this
chapter also provide new information. The entire Draft
EIS/EIR summary has not been revised and included in
this Final because most of its information is still
valid.
3. The comment correctly observes that an inventory of wild
and wetland areas would be needed if a precise estimate of
the acreage of developable land within the general
category of "vacant, wild and wetlands" is to be made.
Because lands assumed to be developable are mingled in
this land use category with lands the Coastal Commission
is mandated to protect (sensitive habitat areas in the
coastal zone, for example), there is concern that the
methodology, by treating this land use category as the
residual after development, may inadvertently commit
(on paper) important natural resource lands to develop-
ment.
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The EIS/EIR was intended to provide insight into the
potential land use consequences of growth. The Coastal
Commission's observation suggests that this purpose
was served.
Since the time the Draft EIS/EIR was completed, the
growth management systems of both the city and county
have begun to operate in a manner that will reduce
the possibility of adverse impacts on wild and wetlands.
First, by slowing the rate of population growth, the
pressure to develop land for urban use will also decline.
Second, both City Measure 0 and County Measure J will
have the effect of consolidating urban development
patterns. Measure 0 does so by delaying until after
19 90 urban development of a number of areas the measure
specifically designates greenbelts. Measure J does
so by setting lower growth rates in rural than in urban
areas and by establishing an urban services line beyond
which urban services will not be extended. Measure J
also establishes as the policy of the county "to prevent
the division or other development of lands which contain
timber resources, mineral resources and wildlife habitat
or other natural resources" except where mitigated.
4. The California Coastal Act of 1976 contains a variety
of policies that will have a strong influence on future
development in the Santa Cruz facilities plan service
area. Those mentioned in the Coastal Commission letter
of comment are summarized as follows:
Concentration of Development: Section 30250 of
the Act mandates that new development be located within,
contiguous to, or in close proximity to existing developed
areas that are able to accommodate it. This policy
is aimed at protecting coastal resources from sprawl
and minimizing the public cost of providing service
to new development in the coastal zone.
Protection of Agricultural Lands: Sections 30241
and 30242 of the Act promote protection of prime agri-
cultural land and lands suitable for agriculture. These
land resources are to be maintained and available for pro-
duction of agricultural products rather than converted
to other uses unless their viability has already been
diminished by conflicts with urban land uses. Section
30241 also promotes establishment of boundaries and
buffer strips separating urban and agricultural lands
so that future land use conflicts can be avoided.
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Protection of Sensitive Habitat Areas; Section
30240 of the Act calls for protection of sensitive habitats
from any significant disruption of values. Uses of
these habitats should be restricted to those dependent
on the habitat resources. Development adjacent to sensitive
areas should be sited and designed to avoid degradation
of the habitat values.
Protection of Marine Resources: Section 30230
of the Act calls for maintenance, enhancement and
restoration (where feasible) of marine resources. Emphasis
is placed on protection and maintenance of areas and
species of special biological or economic significance.
Uses of the marine environment must be compatible with
the long-term viability and productivity of coastal
waters and their resources.
Provision of Public Access: Section 30210 of the
Act calls for provisions of maximum access to the coast
for purposes of recreation and other public use, as
long as this access is consistent with protection of
public safety and the rights of private property owners.
Encouragement of Visitor-Serving Commercial Re-
creational Uses: Section 30222 of the Act encourages
development of private land for visitor-serving commercial
recreation use rather than private residential, general
industrial or general commercial use.
5. The State Coastal Commission will be able to hear appeals
of coastal county permit actions only under certain specific
conditions after the local coastal plan has been certified
by the commission. These specific conditions are described
in Section 30603 of the Coastal Act.
6. The comment indicates that the EIS/EIR should address
the land use goals established in Measure O and Measure J.
As far as residential land use is concerned, this comment
has been responded to in the general discussion of popu-
lation issues ("Supplemental Analyses" section of this
chapter, page 170) and in preceding response #3. Infill will
be encouraged and the overall settlement pattern will
become more dense; a greater proportion of growth will
be shifted to urban areas than would otherwise have
taken place.
Urban nonresidential land use goals and policies do
not appear to have been materially affected by either
measure. (Most of these uses would be in urban areas
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in any event.) In rural areas, Measure J implementation
will help to retain agricultural land in agricultural
use. See also preceding response on wild and wetland
areas.
7. The newly-implemented growth policies of the city and
county will reduce development pressures on agricultural
and other environmentally important lands. This effect
will stem from the parallel moves to reduce population
growth rates and to channel growth into existing urbanized
areas. Measures 0 and J if implemented as planned, will
help mitigate the land use impacts of the wastewater
project.
However, the difference between a 1.4 percent growth
rate under Measure 0 and the 1.6 percent rate in the
Draft EIS/EIR is not very large: 5,400 housing units
in the former case vs. the EIS/EIR forecast for the
Santa Cruz service area of 5,900. If the city grows
at recent state growth rates (1.7 percent) the housing
unit increase over the 20-year period would be 6,800.
8. As the comment points out, historically population and
local employment have been rising at about the same
rate. Both will continue to increase in the future,
but 1) rates of increase will decline and 2) the rate
of increase of employment will exceed that of population.
This forecast is consistent with national trends that
have been noted in virtually every labor market area:
labor force participation rates are on the rise. Speci-
fically in Santa Cruz, this trend reflects rising female
labor force participation rates, the declining proportion
of the population in nonlabor force age groups (both
young and old) and a decline in the proportion of the
population who are full-time students.
9. Neither City of Santa Cruz staff nor analyses of the
county's Measure J impacts indicate any substantial
change in the magnitude of future employment set forth
in the Draft EIS/EIR. A 1979 study commissioned by
AMBAG reportedly indicates a future subregional shift
in employment from the historic core (Santa Cruz-Scotts
Valley) toward Watsonville and the beaches. This shift
will be noticeable by 1990, with that area growing from
about a quarter to about a third of the county's employ-
ment (Freeman, pers. comm.). This shift is not the
result of the growth management policies but rather
the outcome of continued expansion of agriculture-related
business and industry in the Watsonville area.
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As of January 1980/ AMBAG was in the process of dis-
aggregating their population projections. Their Santa
Cruz County population forecast is shown in the following
table.
Year AMBAG Santa Cruz County Forecast*
1985
200,200
1990
211,700
1995
218,100
2000
227,500
*Source: AMBAG, "Regional Economic Base
Study", April 1979.
These figures are very close to the low range countywide
population forecast shown in the Draft EIS/EIR in
Table 3-35, page 137. This table shows a permanent
Santa Cruz County population of 227,000 in the year
1999, as compared to the new AMBAG population fore-
cast of 227,500 in the year 2000.
10. The relationship of Gruen Gruen + Associates population
forecasts for the service areas and the planning for
wastewater facilities was described on page 293 of the
Draft EIS/EIR. Please refer to this discussion for
a full description of the population-planning relation-
ship .
11. Geographic subdivisions of the study area discussed on
pages 121 and 122 of the Draft EIS/EIR are actually
planning subareas, not necessarily service areas.
12. An incremental flow rate using just permanent population
(and students) is typically used by engineers in waste-
water facilities planning because nonpermanent population
estimates are often incomplete or unreliable. More
accurate design estimates have been made by counting
permanent population, measuring flows and then calculating
a gpcd. Flows generated by nonpermanent residents are
obviously accounted for in this procedure; they are
simply assigned to the permanent population's daily
use rate.
Brown and Caldwell has taken the permanent and student
population estimates for the service area (118,040 in
1989) and applied a gpcd rate to those numbers that
actually accounts for flows from the area's nonpermanent
residents. Gruen Gruen + Associates service area estimate
of permanent, student and nonpermanent residents is
175,520 by 198 9. This total population can be served
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by the facilities designed by Brown and Caldwell, using
the permanent population flow rate multiplier. The
SWRCB fundable population estimate of 128,515 does not
include nonpermanent population. It is based on the
statewide D-100 population forecast series, and is the
result of allocating a county total population to the
service area portion of the county. Because the facilities
plan estimate of service area population is lower than
the state's maximum grant-fundable estimate, the facilities
plan numbers are being used to design facilities.
In summary, the City of Santa Cruz is not planning to
increase its wastewater treatment plant capacity. The
city will maintain its wastewater treatment plant at
its existing 21 mgd capacity (ADWF). The grant eligible
capacity will be determined by the SWRCB based upon
the population projections. The city will pay for
these incremental costs over that determined to be
eligible by the SWRCB (approximately 16 mgd of the
flow capacity is likely to be grant eligible not the
21 mgd to be constructed by the city).
13. Figure 1-2 does contain a large number of boundary lines,
but each individual line can be traced with careful
scrutiny. It was felt that the relationship of the
various boundaries was important enough that they should
all be included on the figure. The relationship can
be more clearly pictured if each boundary is traced
with a colored pencil.
The secondary reclamation area is a separate subunit
of the planning area. The dotted dividing line is located
immediately west of Majors Creek. The northern boundary
of County Area A is coterminous with the southern boundary
of the Scotts Valley service area; it does not extend
up into Scotts Valley.
Production of a service area boundary map of sufficient
scale to discern individual streets is not practical
for inclusion in the EIS/EIR. Anyone desiring this
level of mapping detail should contact the City and
County Public Works Departments.
14. This information is included in the population portion
of the "Supplemental Analyses" section (page 170) of
this chapter.
15. As used by the U. S. Census, "household head" is a house
hold's primary wage earner. If there is more than one
wage earner, the individual with the higher earnings
is considered the head of household. This definition
of household head has received much criticism in recent
years, particularly by feminist groups. In the 1980
census, the household head will simply be the first
adult named on the household's census questionnaire.
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The concept of household head is useful in population
and labor force forecasting because it translates employ-
ment data into household data. If the proportion of
households with multiple wage earners increases, then
the headship rate declines. This is the case in six
of the eight major occupation groups listed in Table E-4,
p. 519 of the Draft EIS/EIR. The aggregate amount of
income the household earns is irrelevant to this cal-
culation - only the number of wage earners is involved.
16. The comment questions the difference between an average
county household size of 2.56 reported in the 1976 Special
Census and the Gruen Gruen + Associates estimate of
2.9 persons/household in households with employed heads.
This difference is explained by the fact that house-
holds without employed members are usually composed
of retired people who generally have smaller households.
The county persons/household figure has declined slightly
since 1976; it is reported by the State Departments of
Finance to be about 2.54 in January 1979. The very
slight gradual decline in the number of persons/household
in households with employed heads assumed in the Gruen
Gruen + Associates forecast is appropriate.
17. The Draft EIS/EIR sets forth total vacancy rates of
14.6 percent and 12.4 percent, respectively, from the
1970 and 1976 censuses, and outlines the reasons for
believing 1) that most of the vacancies are accounted
for by units held for seasonal or occasional occupancy
and 2) that the proportion of such units will decline
steadily as the county becomes a more "mature" housing
market.
The 1979 county vacancy rate reported by the State Depart-
ment of Finance is 11.3 percent, which is higher than
the 8-10 percent rate cited in the Coastal Commission's
comment (based on the county's Housing Report - Growth
Management Plan, 1978) but lower than Gruen Gruen +
Associates figure of 13.1 percent in the Draft EIS/EIR
indicating the vacancy rates are dropping more rapidly
than projected. This trend is not surprising in view
of the overall state housing shortage.
However, the long run vacancy rate assumptions in the
Draft EIS/EIR, which show overall rates declining to
the state average and the proportion of part-time housing
units in the stock declining from 11 percent to 2 percent,
continue to seem eminently reasonable. In fact, the
Gruen Gruen + Associates 1979 forecast of 8.3 percent,
part-time units is quite close to the difference between
the Department of Finance's overall 1979 vacancy rate
(11.3 percent) and the county's 1978 estimate of vacant-
for-sale-or-rent (2.3 percent).
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18. Population forecast requirements of the Clean Water Grant
Program are contained in Section 2133(c)(1) of the Cali-
fornia Administrative Code, Title 23, Waters, Chapter 3,
SWRCB. This section stipulates acceptable sources of
population projections and indicates that eligible
capacity is to be based on projections in effect when
preparation of a facilities plan is authorized.
19. These comments are responded to in the "Supplemental
Analyses" section (page 170) of this chapter (see the
population update discussion).
20. This updated information is noted and hereby included
in the EIS/EIR.
21. Much of the water quality data reported in the Draft
EIS/EIR was taken from the AMBAG Water Quality Management
Plan, Final Report, published in 1973 (Yoder-Trotter-
Orlob & Associates, 1973). Since that time there has
been considerable scattered residential development
in the hills along Santa Cruz County's north coast.
This undoubtedly accounts for the increasing occurrence
of fecal coliform contamination of streams draining this
area.
22. Wilder Ranch State Park is located about 400 feet west
of the West site and Antonelli's Pond is located 1,400
feet to the southeast.
23. The following updated description of the California
Coastal Commission is taken from Brown and Caldwell (1978c,
page 3-47).
"California Coastal Catiission. Planning and regulatory pro-
cedures for land use conpatible with the California coast were
established by the voters in the Coastal Zone Conservation Act
of 1972. Hie initiative called for the development of a coastal
land use plan, complete with regulatory procedures, for submittal
to the Legislature by 1977. If the Legislature failed to adopt
the plan, the ccmnission would cease to exist.
Hie Legislature incorporated the key issues of the coastal
plan in SB 1277 which was later approved and titled the California
Coastal Act of 1976. Under this act, a permanent state commission
with six regional oomrtissions was established. The regional
cormissions were to stay in operation until JUne 30, 1979. Each
local government lying in whole or in part within the coastal zone
must prepare a local coastal program or request the regional
ocmmission to prepare one. Until the local programs are certified,
both private individuals and public agencies must obtain coastal
development permits for all proposed developments. Once the local
programs are certified, coastal permits will no longer be required,
but local planning agencies must determine that development proposals
conform to local programs. Local agencies are required to sufcmit
their programs between July 1, 1978, and January 1, 1980. Programs
prepared by the ccrnnissicn shall be ocnpleted by July 1, 1980,
and certified by December 1, 1980.
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The project study area is in the central coast region which
includes the coastal area of San Mateo, Santa Cruz, and Monterey
Counties. The staff is located in the City of Santa Cruz. Initially,
the Central Coast Regional Commission developed a plan with an
inland boundary to the highest elevation of the coastal mountain
range and a permit area 1,000 yards inland from shore. The planning
and permit areas are now the same and extend inland for about five
miles in rural areas and 1,000 yards in developed areas.
24. The size of the proposed wastewater facilities would
be the same under each alternative (except NP^ and NP2).
The 1989 average dry weather flow (ADWF) capacity is
expected to be 16 MGD and the 1999 capacity is expected
to be 21 MGD.
25. The consideration of innovative and alternative technology
in facilities plans was mandated by amendment to the
Clean Water Act in 1977. Plans begun after October 1,
1978, must consider innovative and alternative technology.
While the project report preparation and publication
preceded the publication of the regulations and guidelines,
most aspects of the innovative and alternative evaluations
were in fact considered during facilities planning.
Alternative Technology. Guidelines published September 27,
1978, (40 CFR Part 35, Appendix E) identify specific
alternative technologies that are eligible for enhanced
grant funding. Almost all of these categories were
studied in detail as summarized in the following sections.
Land Treatment. Various types of land treatment
were analyzed in the project report. Alternative LD.
consisted of year-round land disposal of secondary erfluent.
Other forms of land treatment systems were found in-
feasible in the project report because of technical
and institutional reasons (pages 8-54 and 8-55 of Brown
and Caldwell, 1978c).
Aquifer Recharge. Aquifer recharge was investigated
only m the Pajaro Valley, since at the time of the study
it was believed that groundwater withdrawals were below
safe yields in the upper county area. Because of the
State Department of Health restrictions on direct re-
charge, investigations of aquifer recharge concentrated
on the creation of a seawater intrusion barrier via
groundwater injection and extraction along the mouth
of the Pajaro River (Alternative OD/RE^).
Aquaoulture. While not considered in detail during
the planning study, aquaculture was investigated after
completion of the project report in response to interest
expressed at public meetings. Details of the analysis
are presented in the "Supplemental Analyses" section
of this chapter (page 186) .
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Direct Reuse (Nonpotable). Large-scale industrial
reuse of municipal effluent was found to be technically
infeasible because of water quality considerations or economics
(page 7-8 of Brown and Caldwell, 1978c). Agricultural
reuse was studied in a variety of configurations (RE,,
OD/RE^ through OD/REg) covering both local, small-scale
projects and regional, large-scale projects.
Horticulture3 Revegetation of Disturbed Lands,
and Containment Ponds. These alternative technology
categories were not considered in detail in the project
report since it was felt that there were very limited
opportunities for their application.
Treatment and Storage Prior to Land Application
and Pre-application Treatment. All alternatives en-
compassing land application considered treatment and
storage requirements.
Land Application of Sludge. Land application of
sludge was considered in the project report but was
discarded on technical grounds (pages 8-53 and 8-54
of Brown and Caldwell, 1978c).
Codisposal of Sludge and. Refuse. Codisposal was
intensively investigated during the study. In addition
to an array of sites, a total of 13 different types
of technology was investigated (Brown and Caldwell,
1978) .
Anaerobic Digestion with Methane Utilization. The
project report recommends continued use of the anaerobic
digestion process at Santa Cruz. Current use of methane
gas is for generating the power required for making
chlorine gas. Other opportunities for power use can
be examined during the detailed design of the recommended
facilities.
Self-Sustaining Incineration. Incineration was
rejected as an alternative because of its high costs
(page 8-53 of Brown and Caldwell, 1978c).
Individual and On-Site Disposal Systems. Since
most of the tributary population in the facilities planning
area is currently sewered, the opportunities for study
of individual and on-site disposal, systems were somewhat
limited. In the La Selva Beach area, it was recommended
that service continue to be provided via septic tanks
(pages 8-56 to 8-58 of Brown and Caldwell, 1978c). Septage
treatment is considered in Chapter 10 of Brown and Caldwell
(1978c) .
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Innovative Technology. To qualify as innovative
technology, a project element must not be fully proven
in the circumstances of its use and must result in treat-
ment cost or net primary energy savings. A strong concern
for reliable treatment to meet the relatively stringent
ocean plan standards caused relatively unproven technology
to be disregarded by the facilities planning study.
The motivation for this concern was both the need to
meet the ocean plan standards and to protect the
relatively sensitive recreational and scientific uses
of the nearshore ocean environment. As a consequence
potentially innovative technology that had risk concerns
related to effluent quality was eliminated early in
the screening process. (An example is OD-/ trickling
filters; page 8-63 of Brown and Caldwell, 1978c).
It is notable, however, that should the city obtain
a waiver in secondary treatment requirements, Alter-
native OD., is the least expensive and least net primary
energy using alternative considered in the project report.
It is also substantially less costly and less energy
intensive than a solar aquaculture system.
Potentially innovative projects were considered during
the analysis of the reclamation alternatives. Alter-
native OD/RE- is potentially innovative since few recharge/
extraction barriers have been constructed. The project
report recommends pilot tests of Alternative 0D/RE7.
Also, Alternatives 0D/RE5A and OD/REsb may be innovative
as they involved transport:, storage , and treatment
for irrigation reuse. The innovative element of these
alternatives involves a less expensive form of tertiary
treatment than called for by the State Department of
Health in Title 22.
Selection of an alternative site was based on four criteria:
a. Proximity to the existing site.
b. Proximity to the ultimate disposal site.
c. Sufficiently removed from residential and
commercial areas.
d. Adequate available land.
The west side of Santa Cruz offers the only area that
satifies all these criteria. The primary reason for
relocating the treatment plant was the shortage of land
and its proximity to surrounding residential and commercial
areas. The east side of Santa Cruz is also highly developed,
and there is a shortage of available land. In addition,
the Central Coast Regional Water Quality Control Board
66
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prohibits discharge into Monterey Bay from Point Santa
Cruz to the Pajaro River. Therefore, an outfall in
this area would have to extend beyond this line or effluent
would have to be transported to a suitable outfall site
on the west side of town. The Santa Cruz Planning Depart-
ment has identified the west side of town as an area
for future industrial development. There are currently
several industries located in this area; residential
development is at a minimum, and it is an ideal site
for an outfall due to oceanographic conditions as well
as the fact that it is outside the prohibited discharge
area. Since this area is close to both the existing
site and the outfall site, transportation costs would
be at a minimum. There is also adequate land available
for future plant expansions (Brown and Caldwell, pers.
comm.).
26. The reader is referred to pages 341-344 of the Draft
EIS/EIR for further discussion and support for this
statement.
27. Table 7-4 (page 322) of the Draft EIS/EIR compares fre-
quency of expected onshore vector hits for the various
ocean outfall alignments. This information was developed
by Kinnetic Laboratories, Inc., of Santa Cruz, a sub-
contractor to Brown and Caldwell in preparation of an
oceanographic report (Brown and Caldwell, 1977e and
1978b).
There is no reliable method of predicting the frequency
of wastewater treatment plant malfunctions. This depends
upon a variety of factors including the knowledge and
abilities of the treatment plant operators. It would
be misleading to attempt to predict the frequency of
malfunctions.
28. Final regulations for modifying the secondary treatment
requirements under Section 301(h) of the Clean Water
Act were published in the Federal Register on June 15,
1979. The regulations provide the criteria by which
EPA must judge any application for a modification of
the secondary treatment requirement. They also stipulate
the contents of an application for modified treatment
requirements under Section 301(h).
The City of Santa Cruz is seeking a modification of
the secondary treatment requirement, and in that regard
filed its application with EPA on September 13, 1979.
EPA must now review the application to determine if
it is complete and provides all of the data needed to
67
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make a determination. The Santa Cruz application was
required to include a schedule for planning, design and
staged construction of secondary treatment facilities
as well as those advanced primary facilities planned
under Alternative OD7. Planning and design work must
continue during EPA action on the modification request.
There is currently no firm estimate of when EPA will
rule on the application.
29. In February 1979, EPA changed the federal primary and
secondary standards for ozone from the previous level
of 8 pphm (parts per hundred million, by volume) to
12 pphm. In addition, EPA changed the procedure to
be used for determining when the federal standard has
been exceeded. Previously, the federal standard was
Violated if ozone levels of 9 pphm or more were monitored
for two or more hours during any year. Under the new
standard, violations will occur if ozone levels of 13
pphm or more are monitored on 4 or more days during
any 3-year period. The state ozone standard of 10 pphm
is now significantly more stringent than the federal
standard, since the state standard is not to be equalled
or exceeded.
Discussions with the Monterey Bay Unified Air Pollution
Control District (MBUAPCD) indicate that the North Central
Coast Air Basin is still being considered a nonattain-
ment area for ozone in spite of this change in standards.
This is due largely to the high ozone readings recorded
at Hollister (12 pphm) the last couple of years (Hansen,
pers. coram.) .
AMBAG continues to do the nonattainment planning for
the Santa Cruz-Monterey area. Their original nonattain-
ment plan which was submitted to. the State Air Resources
Board (ARB) in December 1978, failed to show the area
achieving attainment. Therefore, ARB has requested
a time extension for compliance from EPA. If approved,
the area would have until 1987 to lower ozone levels
to those required under the Clean Air Act. AMBAG recently
submitted a new work program to ARB which outlines further
efforts to develop an acceptable nonattainment plan
for Monterey and Santa Cruz Counties. This effort will
include development of revised air quality projections
utilizing a revised set of population projections
for the area (AMBAG, pers. comm.). The revised non-
attainment plan will be coordinated with the new
State Implementation Plan, to be completed in 1981.
It is assumed that the new air quality projections
developed by AMBAG will reflect the potential population
growth effects of recently passed growth management
measures in Santa Cruz County.
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New air quality projections have not been developed
for this Final EIS/EIR.
30. Further discussion of mitigation measures has been
included in several parts of this chapter. Mitigation
of wetland losses is discussed further in the "Supple-
mental Analyses" section (page 176).
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.State of California
The Resources Agency
Memorandum
Jim Bums, Projects Coordinator
Date:
July 30, 1979
Resources Agency
City of Santa Cruz
Department of Public Works
809 Center Street
Santa Cruz, California 95060
Attn: Wilson H. Fieberling, Director of Public Works
From Department of Fish and Game
Subject: Draft Environmental Impact Statement and Environmental Impact Report for
Santa Cruz Areawide Wastewater Facilities Plan, Santa Cruz County -
(SCH 79070310A and 790704I0P)
We have reviewed the subject reports which identify the potential en-
vironmental impacts of the City of Santa Cruz wastewater treatment system.
The objective of the project is to eliminate public health hazards and
water quality problems caused by the existing discharge. The new facili-
ties must bring the City of Santa Cruz wastewater discharge into compliance
with the treatment requirements of the permit issued and enforced by the
Regional Water Quality Control Board.
In general, the report adequately describes potential impacts on fish and
wildlife resources. The degree of those impacts will depend upon the
alternative selected. Freshwater marshes and riparian habitat are of prime
importance to California fauna. Of the five alternatives, a modified OD^B
with seasonal reclamation would be least objectionable from fish and
wildlife considerations. Alternative 0D1, and 0D/RE5 both would destroy
3.5 to 5.5 acres of freshwater marsh and would be the most objectionable
alternative in our area. Alternative 0D/RE7, which destroys riparian
habitat, would be intermediate in its adverse impacts. .Alternative OD^,
with advanced primary treatment, is controversial in regard to protec-
tion of marine communities and water quality. The report correctly states
that there remains considerable discussion between both regulatory agencies
and the scientific community as to the relative desirability of secondary
vs primary treatment of wastewater for ocean discharge.
Director
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California Department of Fish and Game
No response required. The Department of Fish and Game's
concern for loss of freshwater marsh is addressed in
the "Supplemental Analyses" section of this chapter.
7a
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STATE Of CALIFORNIA—BUSINESS AND TRANSPORTATION 'AGENCY
/*-*
U-
EDMUND G. BROWN JR., Govrnor
DEPARTMENT OF TRANSPORTATION
P. O. BOX 3346 RINCON ANNEX
SAN FRANCISCO 94119
(4)5) 357-1840
July 25, 1979
04-SCR-1
SCH# 7907031 OA §
# 79070410P
A-95 Coordinator
State Water Resourses Control Board
P.O. Box 100 .
Sacramento, CA 95801
Subject: Comments on the Draft EIS and R and Supplement to the
Draft EIR for the Santa Cruz Wastewater Facilities Plan.
We will be a Responsible Agency for this project if Work will be
done in the State highway right of way or if work may affect our
facilities or traffic operations. A State Highway Encroachment
Permit will be required for such work.
!• Pipeline construction for Alternative Plan OD43 could cause
severe traffic congestion on Mission Street (State highway
Route 1) between Shaffer Road and Younglove Avenue. To be
adequate for us to issue any permits, the document must provide
more detailed analysis of this major traffic impact and include
specific mitigation measures related to the impact.
2. I We believe the last number on the last line on page 310 should
I be Figure 4-£ as shown on page 210.
Responses and the Final Document (FEIS/R) should be sent to:
Caltrans District CEQA Coordinator
Engineering Services Branch
P.O. Box 3366 Rincon Annex
San Francisco, CA 94119
since they will be needed as part of our encroachment permit process.
Sincerely yours,
T. R. LAMMERS
District Director
By
JERRY F. 0'SHEA, Chief
Engineering Services Branch
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California Department of Transportation
1. The City of Santa Cruz is not pursuing Alternative 0D,B,
so no application for a permit to construct along State
Highway 1 is expected. If for any reason this is changed/
more detailed mitigation measures would be included
in an encroachment permit application.
2. Both Figures 4-3 and 4-4 show the proposed Alternative 0D-B
raw wastewater interceptor route.
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STATE OF CALIFORNIA—THE RESOURCES AGENCY
OFFICE OF HISTORIC PRESERVATION
DEPARTMENT OF PARKS AND RECREATION
POST OFFICE BOX 2390
SACRAMJNTO, CALIFORNIA 95811
EDMUND O. BROWN JR., Govtrnor
SEP 2 7 1979
Mr. Paul De Falco
Regional Administrator
U. S. Environmental Protection Agency
Region IX
215 Fremont Street
San Francisco, CA 9^105
Dear Mr. De Falco:
RE: CULTURAL RESOURCES ASSESSMENT REPORT FOR THE SANTA CHJZ WASTEWATER
FACILITIES FLAN DRAFT JSIS { EPA-9-CA-Santa Cruz-WWTP-79) Santa Cruz
County
Thank you for the opportunity to comment upon the cultural resources assessmant
report referenced above.
Staff review of the referenced report noted several major deficiencies which
make the report unacceptable for fulfilling EPA's mandates under Section 106
of the National Historic Preservation Act and 36 CFR 800. We recommend you
note and correct these inadequacies prior to making any decision concerning
the proposed undertaking.
(1) The archaeological report provides no detailed ethnographic setting.
Prior research into ethnographic patterns of demography and environ-
mental exploitation might have assisted in locating unrecorded sites.
In addition to providing a meaningful setting for archaeological values
located during the survey, the local Native American community should
have been contacted to assist in locating culturally significant resources
and to solicit their opinion regarding suggested testing and mitigation
procedures.
(2) The report contains no statement of current or future research questions
for which the proposed archaeological investigations are to be under-
taken. A statement of research strategy should be included which addresses
current theoretical models to be tested.
3.1 (3) The report relies on secondary published sources to identify potential
J historical resources. No consultation with primary sources is evident.
4. | CO There is a paradox between the statements that all ^proposed treatment
I plant sites, pipelines and new ocean outfall routes were investigated
74
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Mr. Paul De Falco
Page Two
in the field(page 1T6) and "investigators were unable to obtain access
to the site, as pri»te landowners did not give permission to enter the
area"(page V83) "aflHhough not reviewed in the field, we accept previous
Investigators infonation..."(page 486). Judging from the cited state-
ments, a comprehensive investigation was not performed although the area
appears to be highQxr archaeologically sensitive.
Additionally, the report contains no meaningful discussion of feasible alter-
natives to avoid disruption, either from construction or archaeological
excavation, of archaeological resources identified. In lieu of avoidance, the
report suggests a "Phase II test program" be initiated so that "the archeologists
(may) develop research dfcrategy (sic) for protection and/or salvage if deemed
necessary."
Concerning the proposal that several of the unverified sites mentioned in the
report (e.g., SCr-102 aril Mnt-226) require extensive subsurface study, we
cannot condone the use xff public monies for extensive archaeological excava-
tions on sites which mqgr not exist. The report should have fully identified
the existence, location and nature of the sites and provided a statement of
significance prior to
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California Office of Historic Preservation
1. Neither NEPA nor CEQA require that EIS/EIRs contain a
detailed description of regional ethnography. This type
of information is undoubtedly valuable to the professionals
conducting archeological surveys, but of relatively minor
value to the agency staff person or layman interested
in descriptions of project impacts and mitigation measures.
Therefore, no detailed ethnographic setting was included
in the Draft EIS/EIR. It is assumed that the professionals
conducting the archeological field survey had familiarized
themselves with local ethnographic patterns.
Local native Americans will be consulted should testing
for cultural resources or mitigation of impacts to
cultural resources be necessary as part of the Santa
Cruz facilities plan improvements.
2. The archeological investigations undertaken for the Santa
Cruz facility planning effort are completed. The selected
Alternative OD^, involves construction adjacent to the
existing Nearys Lagoon site. No known archeological or
historic sites will be affected by construction of this
alternative. These investigations were undertaken to
determine impacts on cultural resources, they were not
designed as a research project to test theoretical
models or answer research questions. The federal/state
Clean Water Grant Program has not been established to
fund research projects, but to plan for wastewater
facilities.
3. In addition to reviewing numerous written descriptions
of Santa Cruz area history, the National Register of
Historic Places (through October 23, 1979) and a state
listing of California historic landmarks (California
Department of Parks and Recreation, 1975) have been con-
sulted to identify impacts on recognized historical features
The Draft EIS/EIR was forwarded to the Santa Cruz Historic
Preservation Commission, the Santa Cruz Historical Society
and city and county parks and recreation and planning
departments in order to determine if the records search
had missed unrecorded historical features that might
be affected by the project. No additional potential
historical features have been mentioned in comments on
the Draft EIS/EIR.
4. The statement on page 116 of the Draft EIS/EIR that suggests
all proposed facilities sites were investigated in the
field is inaccurate. One previously recorded archeo-
logical site (SCr-138) could not be checked on foot.
Access to this site, which is located on or near the
secondary effluent interceptor planned in Alternative OD/REc
was denied by the landowner. However, this alternative
has not been selected, so site SCr-138 will not be impacted
by the Santa Cruz wastewater facilities improvements.
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EPA strongly supports the philosophy of avoiding disruption
of archeological resources caused by construction or
archeological excavation. Avoidance should have been
mentioned as an effective mitigation measure in the
Draft EIS/EIR. Construction through or archeological
testing of recognized archeological sites would be
undertaken only if no other feasible action is available.
It appears that the alternatives being actively pursued
by the city will not affect known archeological resources.
EPA does not intend to fund subsurface study of sites
SCr-102 and Mnt-226. Thorough analysis of these sites
would only be justified if they were located on property
that would be affected by the proposed project. The
alternatives now being actively pursued by the City of
Santa Cruz would not affect SCr-102 or Mnt-226.
EPA feels that the archeological impact analysis prepared
for the Santa Cruz facilities plan Draft EIS/EIR, combined
with the responses to comments contained in this Final
EIS/EIR, is sufficient to comply with federal environmental
and historic preservation laws and regulations.
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(we-js-4) 13
STATE DP CALIFORNIA — RESOURCES AGENCY
EDMUND G. BROWN JR., Governor
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD-
CENTRAL COAST REGION
1122-A LAUREL LANE
SAN LUIS OBISPO, CALIFORNIA 93401
(805) 549-3147
September 6, 1979
Hearing Officer - HE 154
U. S. Environmental Protection Agency
Region IX
215 Fremont Street
San Francisco, California 94105
Subject: EIS - Santa Cruz Wastewater Facilities
Plan, Grant No. C-06-1106, SCH #79070310
Dear Sir:
Subject EIS has been reviewed. The following comments are offered:
A. Mitigation measures for construction at Neary's Lagoon include creating
new marshland to replace those removed by the new treatment facility.
Before a fair assessment of this mitigation can be made, details of
any such expansion should be presented, both as to location, func-
tional design, and financial impacts upon the entire project.
B. Chapter 7, pags. 341-42 mentions toxicity of a chlorinated effluent
and preference to an unchlorinated discharge.
Disinfection appears to be necessary for consistently meeting Water
Quality Control Plan, Ocean Waters of California bacteriological
characteristics in the receiving water but is not brought out in the
text. The impacts of an undisinfected discharge should therefore
be more thoroughly discussed.
C. Construction of a new treatment facility on the "west side" could
occur on the Walti-Schilling property or on Epistima agricultural
lands. The EIS should compare the area of agricultural lands which
would be utilized by the two building sites and the financial im-
pacts associated with building on the Walti-Schilling property
(specifically, demolition costs).
D. No mention in the EIS is made of affects of a septage receiving
station at the treatment facility as proposed in the Project Report.
The Regional Board staff insists and State Board staff concurs that
the Santa Cruz Facility, as a Regional Facility, accept at least the
volumes of septage included in the May, 1978 Project Report (Table
4-28, page 4-39). The positive impacts of a septage station may
78
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Hearing Officer - HE 154
U. S. Environmental Protection Agency
Re: Santa Cruz Wastewater Facilities
September
Page Two
include eliminating public health hazards by allowing more rapid
repair of septic tank systems, reduce possible pollution of the
San Lorenzo River, maintain septage disposal at an environmentally
acceptable site, and help protect the watershed Santa Cruz relies
pn for its water supply.
KRJ:JWG:nd
cc: State Water Resources Control Board,
Cliff Rice, Jim Lee
State Clearing House
City of Santa Cruz
Brown and Caldwell, Walnut Creek
City of Watsonville
Very truly yours
KENNETH R. JONES
Executive Officer
79
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California Regional Water Quality Control Board - Central
Coast Region
1. Details of a Nearys Lagoon wetland mitigation have not
been developed to date. However, planning for the
mitigation has already begun in order to meet the
requirements of a 404 permit from the U. S. Army Corps
of Engineers. The city has purchased land adjacent
to Nearys Lagoon wetland and part of this area may be
converted to wetland as mitigation if Alternative OD^A
is constructed. Our initial analysis indicates that
this type of mitigation is both technically and
economically feasible, but this opinion can only be
borne out by further work on design, function and
management of the wetland. A further discussion of
this topic is presented on page 17 6.
2. The discussions of chlorine toxicity on pages 341 and 342
were presented to indicate potential impacts on marine
biota. No attempt was being made to advocate discharge
of undisinfected effluent. There is an obvious conflict
between the desire to eliminate chlorine from the waste-
water effluent so as to protect marine organisms and
the desire to disinfect the effluent for human health
reasons. Undisinfected effluent, even when discharged
at a considerable distance offshore and at considerable
depth, could pose a health hazard to boaters, fishermen
and water contact recreationists in the vicinity of
the outfall. Some form of disinfection is undoubtedly
needed, but the potential hazards associated with use
of chlorine must be indicated. Dechlorination (which
is planned as part of Alternatives OD^ and OD_) or
use of some other disinfection medium could avoid the
potential chlorine toxicity impact. An additional
discussion of this issue is contained on pages 6-34
and 6-35 of Brown and Caldwell (1977e).
3. The estimated market value at 197 5 prices for the Walti-
Schilling property is $561,000. This includes $250,000
for the land and $311,000 for improvements. The property
extends from the ocean to north of the railroad tracks
and covers approximately 65 acres. There are two possible
siting options involving the Walti-Schilling property.
The first includes using only the portion of the property
north of the railroad tracks, supplemented with adjacent
agricultural lands. This covers approximately 7.4 acres.
Since this portion of the property includes the improve-
ments, the total cost is $29,000 for the land and $311,000
for improvements, which is approximately $46,000 per
acre. This is three times the value of the land used
for Alternative 0D4B« In addition, costs for demolition
of the improvements must be included. The second option
includes purchasing 37 acres of the Walti-Schilling
property south of the railroad tracks. This would put
80
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the plant approximately 1,000 feet from the coast and
adjacent to a large trailer park. Adverse public
reaction would probably preclude siting the plant in
this area (Brown and Caldwell, pers. comm.).
4. Inclusion of a septage receiving station at the Santa
Cruz treatment plant would have a variety of positive
impacts, as indicated in the comment. The most obvious
benefit would be improvement in the current means of
disposing of Santa Cruz area septage. All septage is
now being trucked south to the Watsonville treatment
plant. This long distance transport consumes a con-
siderable amount of time and energy which adds to the
cost of septic tank maintenance. It is also probably
causing individuals in the Santa Cruz area to delay
needed pumping because of the cost. This delay can
result in local public health hazards and a greater
threat of contaminating ground and surface water in
the vicinity of residences on septic tanks. The heavy
septage treatment load being placed on the Watsonville
treatment plant may also be reducing the effectiveness
of wastewater treatment at that facility.
It must also be pointed out, however, that by accepting
septage, the Santa Cruz treatment facility would be
exposed to a number of serious operational problems.
Septage can contain a variety of materials that are
capable of either upsetting normal treatment plant
processes or greatly adding to the toxicity of the
effluent. It is difficult to regulate what septic
tank pumpers discharge to septage receiving facilities.
Large volumes of heavy metals, pesticides or other toxic
compounds may be pumped into the receiving facility,
making it difficult to meet wastewater discharge standards
and adversely affecting marine organisms near the outfall.
In order to control the dumping of highly toxic materials
into the plant, a monitoring system and bonding of
haulers would be necessary.
The City of Santa Cruz suggests that septage could be
disposed of directly to the Santa Cruz landfill site
rather than to the treatment plant as an alternative.
The city feels the landfill's leachate control system is
now capable of contained leachate within the boundaries
of the site, causing no adverse impacts offsite.
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Strrto of California
TOE ""SOURCES 4GSNCY
Vi emorcndu rn
Mr. L. Irank Goodson
Project Coordinator
Resources Agency
14 L6 Ninth Strec.t
13th Floor
Sacramento, CA 95S14
Dct
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California State Water Resources Control Board'
1. The topic of Nearys Lagoon wetland mitigation is
discussed on page 176 in the "Supplemental
Analyses" section of this chapter.
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BOARD OF SUPERVISORS
(408) 425-2201
COUNTY OF SANTA CRUZ
GOVERNMENTAL CENTER
701 OCEAN STREET SANTA CRUZ. CALIFORNIA 95060
Dan Forbus
(FIRST DISTRICT)
Marilyn D. Liddicoat
(SECOND DISTRICT)
Gary A Patton
(THIRD DISTRICT)
Chris Matthews
(FOURTH DISTRICT)
PAT LIBERTY
(FIFTH DISTRICT)
August 6, 1979
U.S. Environmental Protection Agency
Region IX
ATTN: Hearing Office (HE-141)
215 Fremont Street
San Francisco, CA 94105
RE: DRAFT EIS/EIR: SANTA CRUZ WASTEWATER FACILITIES PLAN
Dear Sir or Madam:
Thank you for the opportunity to resDond to the above-mentioned Draft EIS/EIR.
My comments follow:
Page 4 - Both here and elsewhere (pages 120-143) in the document
where population projections are discussed, the EIS/EIR is deficient in
that it does not consider the growth management systems adopted by the
voters in both the City and County of Santa Cruz. I think the population
limits established under these programs should be explicitly considered
in the final document.
2- Page 5 - The Draft EIS indicates that the region's "Basin Plan"
calls for secondary treatment. What is the legal status of this plan?
The City has indicated that the State supports the advanced primary
alternative. Isn't there a contradiction here?
3. Page 15 - The Draft EIS/EIR indicates here and elsewhere that the
relocation of the treatment olant would stimulate development on the west
side because of the supposed limits on the existing sewer lines to the
Neary Lagoon Plant. This point needs further documentation. Previously,
the major limiting factor on westside growth was said to be the capacity
of Mission Street. Sewer line capacity has not, to my knowledge, been
mentioned in the past as a growth constant. In fact, previous City plans
have projected substantial growth on the westside.
Page 19 - The chart summarizing various mitigation measures is
unnecessarily confusing. The cover letter from EPA states that 0D?
is the selected alternative. The chart should show mitigation measures
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U.S. Environmental Protection Agency
August 6, 1979
Page 2
for this alternative only, or at least, separate the mitigation measures
out for each alternative.
5. Page 139 ¦
8780 by 1999.
The Draft EIS/EIR predicts a UCSC student population of
As I understand it, current estimates are 7500.
6. Page 159 - 161 - In discussing local planning efforts, the Draft
EIS/EIR does not mention Measure "0" for the County or Measure "0" for
the City. These should be included.
7. Page 253 - In discussing the Coastal Commission, the Draft EIS/EIR
does not mention that the Commission previously issued permits to the
City which included conditions to protect the Neary Lagoon's wildlife
refuse. These conditions could affect the ability of the selected alter-
native to be approved and should be discussed.
8. Page 358 - Service Cost Impacts - The information on the monthly service
cost impacts of the various alternatives is not clearly presented in the
draft EIS/EIR. This is obviously critical since this is what the public
(i.e. customers) will actually be directly paying. A chart is needed
showing the existing charges and the likely total monthly charges under
each alternative for the various user groups, I would assume the
additional costs for OD/RE5 would be borne in large part by south county
residents.
cc: City of Santa Cruz Mayor
City Council members
City Public Works Director
Jones & Stokes
Brown & Caldwell
85
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Santa Cruz County Board of Supervisors - Gary A. Patton
1. This comment is addressed in the "Supplemental Analyses"
section of this chapter (page 170).
2. The Basin Plan was developed as a guideline for future
water quality and wastewater management planning in
the area. There is no legal requirement that the planning
guidelines be strictly adhered to, but they do indicate
the judgment of the SWRCB at the time of Basin Plan
publication. Subsequent work on revisions to the State
Ocean Plan, which regulates wastewater discharges to
the ocean, has changed most of the toxic waste standards
from limitations on the quality of undiluted effluent
to maintenance of receiving water quality after initial
dilution of the effluent. This means that the levels
of certain toxic constituents in undiluted effluent can
be much higher than in the past as long as the mechanics
of the outfall and natural dispersion characteristics
of the ocean in the vicinity of the discharge can be
shown to be capable of meeting ocean background quality
standards after initial dilution of the effluent. In
other words, the emphasis is placed on thorough dispersion
of toxic materials rather than removal of these elements.
This change in the Ocean Plan has allowed marine dis-
chargers to pursue use of less than secondary treatment
to meet state ocean discharge requirements. Outfalls
with sophisticated diffuser systems located in ocean
waters with relatively strong and consistent currents
should be capable of meeting the Ocean Plan receiving
water limitations with only primary wastewater treatment.
3. Personal communication with Wilson Fieberling, Director
of the Santa Cruz City Department of Public Works,
reiterated his earlier statement that raw wastewater
interceptor capacity between the western edge of Santa
Cruz and the Nearys Lagoon treatment plant is restricting
further development in that part of the city. Construction
of a new treatment plant on the western fringe of town
would remove this particular development restriction.
However, recent passage of City Measure 0 has led to
revisions to the City General Plan which essentially
eliminate the possibility of further development on the
western edge of Santa Cruz. Therefore, relocation of
the treatment plant to the West site could not effectively
stimulate further development in that area.
4. Alternative OD7 is not being recommended for imple-
mentation by EPA at this time; this is the city's pre-
ferred alternative should it be successful in receiving
a modification of the secondary treatment requirement
from EPA. It was decided not to discuss OD7 in detail
86
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in the Draft EIS/EIR because EPA judged it incapable of
meeting the legal requirements of the Clean Water Act
regulations at the time of Draft EIS/EIR printing. The
city developed a separate supplement to the EIR
portion of the Draft EIS/EIR in order to discuss the
impacts of OD7. Mitigations are discussed in that
document (Jones & Stokes Associates, 1979).
A discussion of UCSC student enrollments is contained
in the "Supplemental Analyses" section of this chapter
(page 174).
Measures "J" and "0" are discussed in the "Supplemental
Analyses" section of this chapter (page 170).
The permit issued by the Regional Coastal Commission
was for development of Nearys Lagoon Park and Wildlife
Refuge. It is the city's understanding that the permit
was issued with the full knowledge of the commission
that some of the city-owned land might in future years
be utilized for sewage treatment purposes. The city
feels that issuance of the permit should not affect
the selection of an appropriate wastewater treatment
plan. There appears to be sufficient open land adjacent
to Nearys Lagoon to create new wetland for any that
might be lost through wastewater facilities expansion
(Fieberling, pers. comm.).
A summary of user costs is presented in the following
table. These numbers were taken from Appendix F of
the project report (Brown and Caldwell, 1978c) and
from a Brown and Caldwell personal communication. User
charges were not developed for other alternatives
except for some preliminary charges which are presented
in Chapter 9 of the project report (Brown and Caldwell,
1978c, pages 9-14 and 9-15). However, user charges
for the reclamation alternatives would be the same as
those for Alternative OD-^ since the same basic secondary
treatment configuration li? proposed. An additional
cost would be imposed on the beneficiaries of the
reclamation portion of the project. At one time, use
of an ad valorem tax on Pajaro Valley residents was
discussed as one approach to defray the reclamation
cost. However, the major share of the costs must be
borne by those individuals using the reclaimed water.
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Table 4. Estimated Annual Service Costs
of Alternatives in Dollars
Existing OD - 1982-83 0D7 - 1982-83
Residential Unit - Single Family
City
36 1
75 1
67
County CSD
44 - 631
96 1
88
John Inglis Foods
21,000 2
195,000 3
105,000
Pacific Coast Producers
195,0003
70,000
Thomas J. Lipton, Inc.
45,000 3
25,000
Salz Leathers
215,0003
125,000
^rown and Caldwell, 1978c.
2Estimate presented by Mr. Ralph IKenworthy of John Inglis Foods at the public
hearing on the Draft EIS/EIR (see page 102 of the public hearing transcript).
3Brown and Caldwell, pers. comm. a.
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(408) 425-2191
Michael Van De Veer
Director
i i
COUNTY OF SANTA CRUZ
701 OCEAN STREET SANTA CRUZ. CALIFORNIA 95060
August 29, 1979
U. S. Environmental Protection Agency, Region IX
Hearing Office (HE-141)
215 Fremont Street
San Francisco, CA 94105
Dear Sirs:
RE: Santa Cruz Wastewater Facilities Plan
Environmental Impact Statement
The following comments address two areas of the Wastewater Facilities Plan EIS:
First, water resource utilization for agricultural purposes; and
Second, discharge aspects in general and in relation to Alternative OD7.
I. In its discussion of groundwater resources in the Pajaro Valley, the Wastewater
Facilities Plan EIR adequately describes the major problems facing Santa Cruz
County agriculture: the Pajaro Valley aquifer is experiencing a serious overdraft
condition. Using the AMBAG 208 Study figure of an annual average overdraft of
17,500 acre-feet per year, the safe yield of the Pajaro groundwater basin is
being exceeded by some 32-39%.
Agricultural use of water in the south county accounts for 90% of the ground-
water withdrawal. If agriculture is going to continue on its present scale in
Santa Cruz County, other agricultural water consumption patterns will have to
drastically change or the groundwater supply will have to be augmented.
The land reclamation alternative for wastewater disposal, OD/REg, and to a
lesser extent, alternative OD/REy, represents an apparent feasible solution
to two water supply problems which should be given highest priority. Land
reclamation of wastewater for agricultural use will, as pointed out several times
in the EIS, offer immediate means to augment and improve water supplies in the
lower Pajaro Valley. This will be a significant beneficial effect on the local
water supply and will directly result in an immediate and long-term very sifnifi-
cant beneficial effect for the continuation of agriculture in Santa Cruz County.
The technological problems associated with water quality and use or public
acceptance do not appear insurmountable. The major obstacle to utilization of
this alternative appears to be cost. The EIS mentions, on Page 249, that federal
grant funding is a possibility. This source of financing should be explored in
more detail to provide a more accurate cost-benefit comparison of wastewater
disposal alternatives.
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II. The following comments are offered on the discharge aspects of the facilities
plan EIS.
1. How can the City Council and the Environmental Protection Agency
approve an EIR that recommends a treatment system that cannot
and, most probably, will not meet the 30 mg/1 B.O.D. and 30 mg/1
SS requirements of federal regulations?
Brown & Caldwell suggest that OD7 plant modifications and/or
increased pretreatment of raw wastewater could be used to meet
the regulations. There was no further explanation. This needs
to be addressed.
The amount of chromium (also nickel, zinc, and arsenic) and the
effect on the marine environment are not documented. How can the
city and EPA allow toxic wastes to be discharged to the ocean,
even after "improving" the treatment system? Doesn't the NPDES
permit control and limit the discharges of toxic wastes? Why
aren't the industries responsible for the chemical and heavy metal
discharges required to remove these contaminants, as required by
federal law?
3. According to the EIR, the wastewater plume will surface and may
contact the shoreline during the winter months. Even a dilution
of 160:1 is "capable of creating a coastal nuisance and public
health problem". Why will this be allowed?
4. The approval of OD7 will delay for 20 years the rational and logical
conclusion that recycling and reuse of wastewater will save money and
create the impetus for growth in the long run. The money savings would
be realized by the reduction in new water source demand and consequently
the reduction in planning/engineering for future water supplies, with
adequate water supplies from the recycling programs and the existing
supplies, the capability for greater residential growth will come. The
one-way system proposed (and existing) will eventually reach an upper
plateau, limited by water supply.
We hope these comments will be useful in the evaluation of the environmental impacts
of the proposed project and in the selection of the most beneficial alternative.
Thank you for the opportunity to comment.
Sincerely, _
<(¦> - - -lut.
Tom Burns
Environmental Coordinator
TB :nj
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Santa Cruz County Community Resources Agency
1. Consideration given to reclamation during the wastewater
facilities planning process is described in the "Supple-
mental Analyses" section of this chapter (see page 182).
This discussion includes a listing of reasons why reclama-
tion alternatives have been rejected to this point by the
City of Santa Cruz. One of the major drawbacks to the
reclamation schemes is cost. Alternative OD/RE5 has an
estimated present worth cost of $64.39 million and OD/RE7
has been estimated at $90.62 million (including Santa Cruz
plant improvements). In comparison, Alternative ODi^ is
estimated to cost about $44.29 million. Extra federal
funds are available to reclamation projects only if they
are determined to be the cost-effective solution to water
pollution problems.
2. The Draft EIS/EIR does not recommend implementation of
Alternative OD7. Alternative ODi^ is considered to be
the selected alternative. (Secondary treatment at Nearys
Lagoon with ocean disposal through an extended outfall.)
While the Clean Water Act requires secondary treatment
it also allows for applications for temporary modification
of the secondary requirement. The City of Santa Cruz
has applied for this modification and will probably
pursue Alternative OD7 (advanced primary treatment)
should that application be successful. The rationale
for and impacts of an advanced primary treatment
alternative is discussed in Jones & Stokes Associates,
Inc., 1979.
3. The NPDES permit, developed and enforced by the RWQCB,
includes specific limitations on discharge of toxic
constituents. This includes arsenic, cadmium, chromium,
copper, lead, mercury, nickel, silver, zinc, cyanide,
phenol, total chlorine residual and ammonia (see
Table 7-5, page 345 of the Draft EIS/EIR). The limita-
tions are part of tlie State Ocean Plan discharge
requirements and are in the form of receiving water quality
standards after initial dilution of the waste plume.
The actual level of toxic material in the effluent is not
limited, but the effluent cannot cause levels of toxic
materials to exceed specific concentrations after the
effluent is initially diluted. The NPDES limitations
must be met, regardless of the level of treatment employed.
The permit's water quality restrictions have been developed
to minimize any potential impact on the marine environment.
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The City of Santa Cruz currently has an ordinance and
monitoring program designed to limit the amount of toxic
material dumped into the city sewer system by industrial
users. This city program must be revised, however,
in order to comply with new State Ocean Plan discharge
standards and EPA pretreatment requirements. Both state
and federal regulations are now encouraging stricter
source control and industrial pretreatment requirements
so that the level of toxic materials flowing into
municipal wastewater treatment works can be minimized.
The City of Santa Cruz must comply with these regulations.
4. According to the analysis conducted by Brown and Caldwell,
the Alternative 1C outfall would be capable of providing
a minimum of 160:1 initial dilution of effluent; this
dilution would occur approximately 1 mile offshore of
Terrace Point. The diluted waste plume would reach the
shore zone from 0.3 to 2.7 percent of the time, depending
upon the season of the year. The minimum dilution expected
by the time the plume reached the shore is 290:1 (see the
Draft EIS/EIR, pages 320 and 322). This slight risk of
shoreline contamination is acceptable when judged against
the hazards created by the present outfall and the costs
of extending a new outfall even farther offshore.
5. The selected alternative is OD]^, not OD7. Recycling
and reuse of wastewater is not precluded by the selection
of Alternative OD^. The treatment and disposal facilities
provided by Alternative (secondary treatment at
Nearys Lagoon and wastewater disposal through an
extended ocean outfall) would be needed in a reclamation
scheme during periods of wet weather when demands for
reclaimed wastewater would be negligible.
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August 30, 1979
U.S. Environmental Protection Agency
Attn: Hearing Office, HE-154 Region IX
215 Fremont Street,
San Francisco, Ca., 94105
I was the first of the public to make a statement at the
hearing held last night here in Santa Cruz. It was unprepared
and since most of the people following me handed in copies of
their statements I decided to put mine in writing also and send
it in to your office.
I am Donald Cleveland and live at 132 Shelter Lagoon Drive -
right on Neary's Lagoon where we can see hear and smell the
sewage treating plant. We can live with the present situation
which we were aware of when we bought our condominium here. It
is part of a 95 condominium/240 apartment complex. Part of the
purchase price went into turning an sightly slough into a beauti-
ful wildlife preserve called Neary's Lagoon. We love it here as
do the many people who use the easement that we have given to the
City of Santa Cruz for viewing the ducks, geese and swans that
inhabit the lagoon.
I and my wife are opposed to any appreciable expansion of
the present plant because it would lower the beauty and desire-
ability of the area as a place to live and enjoy. I think that
secondary treatment is desireable, at least up to the volume
that can be reclaimed in some manner. The biological treating
plant should be located in a presently or potentially less sensitive
area - and if possible to continue using the present primary
treating plant to keep cost down. Of course, it is possible
that operating costs could be less if both treatments were done
in a single complex. If so, please do not do it here at Neary's
Lagoon.
Very truly yours,
Donald Cleveland
SHELTER LASOON AS1"" "'AT'DT
100 Shelter Lagoon Drive
Santa Cruz, CA 95000
93
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Donald Cleveland
1. In order to meet present federal law (the Clean Water
Act), secondary treatment facilities must be added to
the Santa Cruz wastewater treatment plant. The City of
Santa Cruz has, however, applied for a modification
of the requirement for secondary treatment. If the city
obtains this modification, no expansion into Nearys
Lagoon could be expected to take place.
94
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(He-ist) igA
COLLIER'S
EARTHWORM COMPOST SYSTEMS, INC.
CECOMS. INC.
=2sv-7 ^
/lfr~
'SC-c'fc. -fa I'oZ/ot.o o« i"?««f/'/L o^ ^^"f;oiji|ji3l'/i'(|,
"7
-------
VERM ICOMPOST'ING (Earthworm Composting) : £ ^ ^ '3 5 £
Vermicomposting is the term used to define the process in which
largo quantities of earthworms, with proper management, are used in
the conversion of tons of organic waste into a rich, marketable soi : .
California ana Washington State have recently, through legisla'.ion,
recognized vermiculture as part of the agricultural industry.
BACKGROUND OF CECOMS, INC.;
Collier's Earthworm Compost Systems (CECOMS) was incorporated
in May, I978; however each of its participants has several years of
vermicomposting research as background.
Jack Collier, President, has six years of research experience
vermicomposting sludges. He is a graduate of Montana State University
holding a B.S. degree. Recently, Mr. Collier left an engineering career
of nearly 20 years with Western Electric Company in order to pursue
vermicomposting on a full time basis. The past two years of Mr. Collier's
research has been funded by a grant from the National Science Foundation
supporting on-site research at the San Jose/Santa Clara Wastewater Treat-
ment Plant.
Diane Livingstone has been affiliated with CECOMS for the past
year having left her career as owner and operator of a successful private
school. Ms. Livingstone has a B.A. degree from University of South
Florida where she was trained as a researcher. She has six years of
research experience concerning the role of the earthworm in agriculture,
educating others in the importance of the earthworm in relation to the
food chain :-.-.nd is currently conducting plant growth comparison studies
under National Science Foundation grant funding using earthworm manure
(castings) derived from sludges.
96
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c.Iii'.riii'icant volume reduction of organic wastes results fro::, v r:r.i-
cornpostj ng.
'") .iTcnsi v odors are eliiuinatod in the vermicompoting proc.?:.:.
A fertile riarkc.-tablo soil product results from CEC01".;3 vormicompostin.
and harvesting techniques.
Vr-nni compos ting is :
1. Economical.
EnvLronmentally sound - having no air, water or land pollutants
a r i s ing from the p r o c c s s .
3. Energy efficient - low technology requires minimal fuol
consump tion.
. Mo* labor intensive.
Sludges are fully stabilized. Castings derived from, sludges may
ho used on plants without burning effects. Earthworm manure is a
na lural so il produc t.
Transportation costs may be eliminated or substantia l J.y reduced
by vcr;:iicorr:posting on or near the site at which waste is produced,
ilisv'i volume reductions of the waste during vermicomposting contribut
to lov/ij;- transportation costs from site to market.
'Waste becomes a resource recycled for appropriate us';.
CapitaJ >¦ quipmont costs arc very low.
"To ke, \neJocUjd u>itk. Q__
vjack. Cc\te ^ Y-0,6cx &U6 C 2 G» <
"ike- v^cuorrj Sai/i.WVuz- uiasWuztUrr
far- }l,S.iOfiLR£JL.
97
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16—Santa Cruz Sentinel — Sunday, August 26, 1979 $£•> JI j qj njU
Earthworm Panacea
For World's Woes?
By BILL NEUBAUER
Sentinel Staff Writer
There's a little creature that
just might help to solve one of
the nation's biggest waste dis-
posal problems, save energy,
create a fertilizer supply and
even provide a source of pro-
tein.
It's the earthworm, accord-
ing to Jack Collier, president of
Collier's Earthworm Compost
Systems, Inc., of Santa Cruz.
And the National Science
Foundation agrees with Collier
that the little creature may-
have great potential as a pan-
acea for many of the worlds
major problems and needs. It
has given Collier $25,000 for a
two-year study of that poten-
tial.
"The earthworm's potential
as a panacea comes from its
ability to digest raw soil and
manure, extracting the
nutrients and excreting the rest
as an extremely rich substance
known as earthworm cast-
ings," Collier said.
A handful of scientists, engi-
neers and earthworm growers
now see the earthworm coming
to the rescue in the nation's
wastewater treatment plants,
which are coping with millions
of tons of sludge annually at a
cost of $1.5 billion. Collier said.
Sludge is derived from hu-
man waste and other organic
materials removed from waste-
water during treatment. It is
mounting up at near crisis pro-
portions in many of the nation's
90,000 cities, Collier added,
where the traditional choices of
dumping it on land or in water
or burning it are growing less
desirable because of space lim-
itations and environmental re-
strictions.
What to do with all the
sludge?
COLLIER'S
EARTHWORM COMPOST
Using his two-year grant on a
research project sited at the
San Jose-Santa Clara sewage
treatment plant's sludge
lagoon, Collier said he has dem-
onstrated that with proper
management and conditioning
of sludges, millions of
earthworms can convert tons of
• sludge into fertile soil suitable
for landscaping, farming and
houseplants.
"Since we are ready to move
from the experimental stage to
fullscale conversion of
sludges," says Collier, "we will
be considering several cities
which would like to change
their organic waste problems
through a lowcost, energy effi-
cient, environmentally sound
process into a marketable prod-
uct."
Collier left a 20-year engi-
neering career to form his cor-
poration.
Diane Livingstone, an as-
sociate, said: "For'thousands
of years mankind has used
earthworms and earthworm
manure to stimulate plant
growth, balance the soil and
change organic waste into plant
food."
Livingstone is researching
utilization of earthworms in ag-
riculture. and she reports:
"We are harvesting the first
food crop-corn-grown on
earthworm castings derived
from sludge. The crop has been
analyzed to prove it is safe for
human consumption. We are
looking for farmers to work
experimentally with us on other
crops."
Don Seed, the Corporation's
marketing consultant, said:
"This technique marks signifi-
cant progress for mankind in
economically gaining control of
organic waste disposal."
A farmer who inspected the
rich soil and wants 3,000 tons of
it yearly for his own operation,
has told the company that if it
keeps the product competitive-
ly priced the only problem will
be keeping up with demand.
Collier's Earthworm Com-
post Systems recently in-
troduced a potting mix,
Nature's Good Earth. The com-
pany claims that comparative
plant growth tests have shown
this potting mix, which con-
tains earthworm castings, out-
performs all other competing
products tested to date.
Cities or farmers interested
in a pilot test are invited to
contact Jack Collier, P.O. Box
2910, Santa Cruz, 95063 or to
telephone the company at
425-0801.
I ACtX
It- ^
be
X) iCme- Ui Vj l
(rro iK~b, IT'
~Tffo
)
viqp
h,
SYSTEMS. INC.
98
£>\cl "~pc5->S'i
AfS. UOodk^r:
V
-------
Jack E. Collier
1. This subject is discussed in the "Supplemental Analy
section of this chapter (see page 180).
99
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(HE-/!T4) 10
UNIVERSITY OF CALIFORNIA, SANTA CRUZ
BERKELEY • DAVIS • IRVINE • LOS ANGELES * RIVERSIDE • SAN DIECO • SAN FRANCISCO
SANTA BARBARA • SANTA CRUZ
COASTAL MARINE LABORATORY
DIVISION OF NATURAL SCIENCES
APPLIED SCIENCES BUILDINC
SANTA CRUZ, CALIFORNIA 93064
August 29, 1979
TO:
EPA HEARING OFFICER
RE:
Draft EIS-EIR - Santa Cruz Wastewater Facilities Plan
My name is William Doyle and I am Director of the Center
for Coastal Marine Studies, Santa Cruz campus of the University
of California. I also am a professor of biology and a resident
of the City of Santa Cruz. My comments represent my own concerns;
they do not represent the position of the Santa Cruz campus or
the University of California nor have my comments been cleared
through them. My comments are restricted to the alternates
discussed in the Draft, May 1979 document and are limited here
* . ^
to concern about the ocean outfall alignment and locationAdiffuser
terminus. (Comments concerning primary vs. secondary treatment
are contained in a separate statement.)
The Center for Coastal Marine Studies has its on-shore
marine station, The Long Marine Laboratory, at the west edge of
the Santa Cruz City limits. Its location is immediately on-shore
of the favored outfall alignments and diffuser location, regard-
less of level of treatment of sewage and location of the treat-
ment plant (Neary's Lagoon area or west Santa Cruz.) The marine
lab is designed to support research and instructional activities
where access to running seawater is required. The first phase of
construction is completed and research labs, tanks for holding
~
marine mammals and a public aquarium room are completed. Schematic
drawings are underway for an analytical research building to
support environmental quality/toxicology research and related
activities. Present research includes studies on adult marine
animals and plants, fertilization, larval development, settling
and metamorphosis, neurophysiology, membrane function, aquaculture
research, and screening for antiviral and other marine natural
products of potential use to humans. The new analytical facilities
now being planned will support a heightened level of sophisticated
100
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research which requires sea water with as low a level of pollutants
as possible. Water quality, therefore, is of great concern to
us.
On page 414, comment is made that "the larger outfall
routes (1C, ID, 3B, 3C and 3X) would afford the best long-term
protection of public health,and coastal water quality which is
the primary reason for relocating the Santa Cruz outfall." I
agree with this statement. The terminus in all cases (ID and
3C essentially are identical diffuser locations, see Fig. 7-1
and Table 7-4) is approximately due south of Long Marine Lab.
During most of spring, summer and fall, when the thermocline
is established, the effluent plume will remain below the thermo-
cline and coastal currents will carry the effluent parallel to
the shore and away from beaches and the marine station's saltwate:
intake system. At such time that the plume reaches the surface,
however, the wind driven surface currents, especially during
winter when the majority of our storms come in from the south,
can divert the effluent plume directly toward the marine lab's
intake system. The impact on the water quality will be greater
as the wastewater facility nears design capacity and storm run-
off also is added to the effluent.
There is an increasing awareness of the potential toxic
effects of chlorinated hydrocarbons and organochlorine/bromine
compounds, often in low concentrations, on marine life. Moreover,
heavy metals may have toxic effects. It also is established that
the total concentration or amount of a heavy metal in an effluent
is less significant in many cases than the form of that chemical.
Some chemical forms, for example, of chromium, are much more
toxic than other chemical forms. Moreover, the chemical processinj
of sewage may alter the chemical form, so that while mcxst of the
metal might be removed, the form of the chemical which remains
can be much more toxic than the untreated form. All ocean dis-
charge, whether primary or secondary, is treated (disinfected)
with chlorine. The formation of combined chlorine compounds
(orgaiochlorine bromine and chlorinated hydrocarbon), some of which
have potential toxicity, is assured. Hence the location of the
ocean outfall terminus to the intake system of the marine lab
takes on additional significance.
101
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1
I urge, therefore, that to ensure the highest level of
water quality on our local beaches at Natural Bridges State
Park, Wilder Ranch State Park and at the intake of the Long
Marine Laboratory, that the ocean outfall be required to follow
the ID or 3C alignment, regardless of manner of effluent treat-
ment. Once the diffuser is in place, it is probable that no
amount of deleterious effect? on the marine station's research
and instruction will lead to an outfall extension in a reasonable
length of time. Now is the best time to ensure the highest level
of water quality onshore.
Table 7-4 (pg. 322) compares outfall alignments at Wilder
Beach and Terrace Point (site of the Long Marine Laboratory) and
probability of vector hits and dilution. Note that the probability
of vector hits decreases significantly at Terrace Point when
alignment 1C or 3B is compared with ID or 3C. One can argue
that the frequency of hits is low with 1C or 3B so why worry?
The EIS/EIR discusses unknown effects of toxic compounds (e.g.,
pp. 342-244, 414) in low concentrations on water quality. I can
neither prove that there will be an effect; the report does not prove
that there will not be an effect. Note also that the vector hit
analysis does not include the months of November, December and
January during which time this area receives significant storms
from the south.
In conclusion, I raise concern about the outfall alignment
and urge that alignment ID or 3C be selected as the one best
designed to guarantee the highest onshore water quality.
Sincerely,
William Doyle
Director
102
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William Doyle
1. The longer ocean outfalls (ID and 3C) considered in the
facilities plan would provide a higher degree of pro-
tection to beneficial uses of the coastal waters around
Terrace Point, as you have indicated. Route 1D/3C would
provide at least a 46 percent higher minimum dilution
at the shoreline than Route 1C in most months according
to figures developed by Brown and Caldwell (see page
322 of Draft EIS/EIR). This does not include an analysis
of the peak storm months (November-January) as you point
out. The lower expected frequency of effluent field
contact with the shoreline is also worthy of note. However,
this extra protection would cost an estimated additional
$1,350,000 in construction costs when comparing routes
1C and ID (Brown and Caldwell, 1978c, pages 7-11).
Further, the predicted shoreline dilutions for Route 1C
exceed shoreline dilutions required to protect marine
life according to the revised California Ocean Plan.
After weighing the cost difference and the incremental
increase in shoreline protection, Brown and Caldwell
recommended Route 1C for implementation.
103
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CUCT-/S4) 18
A RESPONSE TO THE EIR/EIS SANTA CRUZ WASTEWATER
FACILITIES PLAN - August 29, 1979
Respectfully Submitted by,
Santa Cruz City Energy and Urban Services Task Group
Represented by Ronald Pomerantz
509 Seaside Street
Santa Cruz, CA. 95060
The present sewage outfall extention was completed in 1958.
The bond issue used to finance this project amounted to
$^50,000. Now, some twenty years later, we are told it's time
again to sweep the problem under the rug with a $2.5 million
bond. The result would be a new, wider, and longer pipeline
that enables more sewage dumped further into the ocean that will
contain heavier doses of chemicals.
Twenty years down the road we'll be faced with a far worse
problem. All we'll have to show is a tens-of-millions-of-dollars
boondoggle. Local businesses concerned about costs now, will be
five times more concerned at the century's end. As time goes on
the employment pictur^lso becomes bleaker. A long-term, pro-
gressive approach to sewage management can, and must, address
the quantity and quality of jobs in the Santa Cruz area.
Each step of the way Brown and Caldwell and the Public Works
Department claim plan 0D-7 is our best choice. They say it will
be a mere $30 million system for twenty years. That was in 1976
dollars. No mention of the debt service is made anywhere. Nor
is the monthly cost increase^) to 'ratepayers.
A fundamental flaw in plan OD-7, and to a lesser extent 0D-1,
our future options will be hamstrung, if not completely closed.
104
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In addition to monies not available, the ability to move towards
less energy and chemical consumption will have been prevented
by OD-7 or OD-1. Engineering designs are geared to encourage
increasing need and usage of water, chemicals, and energy rather
than the opposite.
The aim of our sewerage system should be providing
employment by reclaiming water and other resources at the
least possible harm to the environment. This means designing the
treatment plant to utilize the methane and sludge, weaning
dependence from chemicals and non-renewable fuels, and en-
couraging water conservation.
According "bo Brown and Caldwell, by 1997 > some fifteen years
after the capital constrution is completed, it will cost nearly
$6 million per year for the treatment plant's operation and
wv tW A*
maintenance alone> This figure does not^land disposal costs.
We must also question the accuracy of Brown and Caldwell's energy
and chemical costs in light of diminishing petroleum reserves
and increased monopoly control over these resources as evidenced
by the 75tf° price increases of petroleum within the past year.
Not only are capital and O&M costs accelerating faster than
can accurately predicted, but Brown and Caldwell failed to show
how revenues would off-set initially higher capital costs under
reclamation alternatives. No income from water reclamation or
sludge sales would accrue from plans 0D-? or OD-1. If North
Coast farmers paid what they are paying now, roughly 100/1000 gal.,
the City would earn over $160,000 per year in selling 5000 acrefeet
per year of reclamed water. I was unable to obtain costs for
processing sludge. But obviously sludge could generate income
105
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-3-
for Santa Cruz as it has already done in the Chicago area. This
wcruld also save dewatering, transportation, and landfill costs;
all left unaccounted for by Brown and Caldwell. As water and
fertilizer use is maintained or increased, and existing supplies
diminish over the next twenty years, these resources value will
go up as well. Such a plan will detain the need to go
ahead with the proposed $25-$5° million Zayante Dam and
Resovoir and prevent the need to spend lOO's of millions of
dollars for off-shore drilling in Monterey Bay.
Other alternatives addressed by Brown and Caldwell covering
reclamation are all the most capital heavy systems imaginable
and are doomed to fail. No mention of aqua or poly-culture
systems which are safer, provide more good jobs, and cheaper in
the long-run. No mention was made of hybridy6r a combination
system as what the Monterey region plans call for. In Santa Cru:
this could mean upgrading the Neary Lagoon plant to a secondary
treatment and pumping this effluent to settling ponds on the
far West side in order to obtain advanced secondary or terciary
quality reclaimed water. Or keeping Neary Lagoon as a primary
treatment plant and pumping only what's needed for further
treatment on the far West side; keeping adequate land for future
expansion as needed.
106
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_/4-_
Brown and Caldwell was contracted by the Santa Cruz City
Government in 1975 to do the Wastewater. Facilities Planning Study.
This study, costing over a million dollars, is riddled with
bias, limitations, inaccuracies, and incompletion as already
evidenced by my report and those who have already addressed you
and will soon do so. Many of these problems are a reflection
of the prejudices within those who run the City Government.
Other flaws are attributable directly to the engineering firm of
Brown and Caldwell.
Their major bias includes the fact that they are doing a
study that will keep them in business, provided their conclusions
are convincing enough. Many problems today are directly
attributable to inadequacies in the Sewage Collection and Disposal
report that Brown and Caldwell did in 1963 for Santa Cruz. There
is little incentive for them to design a system that would
eliminate their future participation.
Brown and Caldwell is a steel and concrete engineering firm.
They have no licenses to design , nor construct, any alternative
sewerage system. Their study, and the EIJV'EIS, failed to include
biological secondary or terciary (aqua or poly-culture) systems
as alternatives. Should these alternatives be implemented^ the
need for the $20 million new outfall would be elininated. The
green light for the new outfall means a million income for
Brown and Caldwell.
Short-changing reclamation alternatives is also in Brown and
Caldwell's best interest. They did the 1963 Water Supply and
Distribution report for the City of Santa Cruz. Nowhere was any
mention made of conservation or reclamation. Their empasis waa
107
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-5-
on a series of dams and reservoirs and the necessary distribution
networks. This makes sense for Brown and Caldwell in order to
keep them in business. However it doesn't make sense for the
ratepayers or the environment.
Brown and Caldwell also conceeded their bias towards protecting
business interests at the expense of comima;nity and environmental
concerns. Such a position was publicly stated on August 21, 1979
at the educational session of the Santa Cruz City Council. They
believe it's most appropriate that Santa Cruz residents and the
environment subsidize short-sighted business profitability.
The Proposition 13^could be used to help pay for a better sewer
system. Federal, State and/or local loans or grants could off-set
undo hardships for the tannery, the canneries, and Lipton. These
are the major sewage contributors with some of the treat-
ment plant's average load, and account for the great majority of
6 the heavy metals, salts, and other toxins. These businesses
should pay for what they are responsible for.
Sewer rates are based on 80of a business' water use. In
other words, businesses are charged by the quantity of their water
use, not on the quality of their sewage discharge. For example,
a school that uses more water than the tannery is implicitly
considered by the Brown and Caldwell Study a worse strain on the
treatment plant. What this raises is a methodological problem,
and not dealt with by Brown and Caldwell. Small quantities of
water use, therefore sewage volume, does not necessarily mean
significant amounts of harmful substances are not flushed into
the public sewers. The Brown and Caldwell Study, nor the EIR/EIS,
7 | mention the local mushroom industry that routinly discharge
108
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-6-
| fungicides and pesticides. (This information is of significant
' consequence, in particular under OD-7, as the increased use of
chlorine will increase the likelihood of chlorinated hydrocarbons
being produced.) The quantity, and more importantly, the
quality of hospitals' sewage was not addressed. The most
glaring oversight in either report being the electro-plating
operations that reportedly discharge millions of gallons annually
into the sewers.
Since heavy metals and high salinity are major reasons Brown
and Caldwell found reclamation economically unfeasible, why did
they fail to address on-site recovery? This evades Public Law
92-500 that requires pre-treatment. This requirement for the
major polluters could alleviate vast public expenditures at the
treatment end and allow for reclamation plans to be implemented.
Such planning would also save energy costs and in the long-run
save these businesses money as their supply costs rise. Under
plans OD-7 or 0D-1, under your (EPA) own standards, ammonia will
be discharged at 3 "to ^ times above permissible rates. Inconclusive
proof has been presented that safe levels of arsenic and chromium
will be discharged. On-site treatment and/or significant upgrading
at the treatment plant will be essential to meet these minimal
standards, that will undoubtedly become more stringent in time.
The issue before us is painted as a choice between advanced
primary and secondary treatment. Admittedly there are problems in
both. But what must be addressed is the eventual need to go
beyond secondary treatment in order meet the "Era of Limits" by
utilizing sewage as a resource. The only way to meet our future
needs is by preparing now. This means building a secondary
109
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-7-
treatment now, with the intent to upgrade the treatment on a
planned "basis in order to avoid a crisis situation.
This points to a fundamental problem with the entire Brown
and Caldwell Report; Future planning is sacrificed for short-term
expediency. A question not addressed is how do we deal with pres-
ent sewage problems and prepare to meet future needs and require-
ments. Brown and Caldwell tell us for the present to just dump
it further into the ocean. There's no future addressed.
Brown and Caldwell project a doubling in volume of sewage within
the next twenty years. Existing water supplies cannot come close
tc fulfilling the demand required in this prophesy. We can only
assume that new, major water projects are in store. No mention of
the environmental, social, or economic impacts of such a plan are
discussed, let alone comparing this plan to water reclamation.
This is especially important in light of the fact that the planned
Zayante Dam and Reservoir would flood hundreds of acres, sit some
300 feet from an active earthquake fualt, and cost some $25 to $50
million dollars.
In the draft EIR/EIS supplement a statement on page one says
(leaving 12as the local share)
as much as 75f° Federal and State can be obtained^. No mention
was made regarding implementation of a "new, alternative, or
innovative system" which would qualify loxj&Sfo Federal, 12^ State,
and only 2^ local funding. In other words, rather than local
residents paying $2| million for a $30 million system that will be
outmoded before its built, disrupt ecological balances, and waste
valuable energy and soil nutrients, *he same $2^ million could
conceivably pay for a $100 million system if necessary, if it qual-
ified under EPA guidlines. Such a system could not only be
110
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environmentally more benign, "but would employ more people initially
and over the plant's lifespan.
As time goes on the issue of energy will become more vital.
Today the Neary Lagoon treatment plant is the largest user of
electricity (2j million KWH in 1978) and natural gas (6f billion
BTU's in 1978) in Santa Cruz City. That's equivalent to over
2C$ of all electricity comsumed by the City Government of Santa
Cruz and roughly 2$% of their natural gas usage.
Yet nowhere in the Brown and Caldwell Study of the EIR/EIS
is this issue addressed. The treatment plant presently produces
an average of 98,000 cubic feet per day of "sludge" gas (mostly
methane). Most of this gas is burned off or lost through the
inadequate digestor cover. As the plant handles increased flows
sludge gas production should increase proportioately. Present
gas production could power a significant portion of plant operations
at a minimal expense as there is already a generator on-site.
What is needed are proper fitting digestor covers and storage
I facilities for the sludge gas.
Dewatering of sludge is the second largest user of electricity
at the treatment plant. No figures were available regarding use
of natural gas, though we can assume it is quite significant.
The dewatered sludge is then mixed with sand. It is then trucked
to the land dump site on the North Coast where it is used as a
groundcover for the solid wastes. Along comes the rainy season
and the leachate problem reoccurs. The same problem that compelled
the State to issue a Cease and Desist Order and close the dump
two years ago. The EIR/EIS does not assess the environmental or
economic impacts for the continuation of such an ill-conceived
111
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sludge disposal system. This is especially true in light of new
techniques that enable sludge to be used as a soil conditioner
(for example Golden Gate Park in San Francisco) or earthworm
feed, or generator fuel.
As petroleum resources are further depleted an uncertain
supply and price for energy and chemicals is apparent. According
to Brown and Caldwell, energy costs will increase ten-fold between
1982 and 1999- Chemical costs will also inflate greatly, though
not as. astronomically as energy. Such rapidly escalating prices
indicate potential shortages. Going the route of OD-7 would
put the treatment plant at the mercy of the oil and chemical
monopolies. Witness the recent gas lines and pending heating
oil uncertainties. The treatment plant could not wait a week or
two for a delivery if public health and safety and environmental
standards are to be maintained. We believe the only reasonable
long-term solution is aiming towards local self-reliance, and
mininizing our dependence on overly centralized, mass systems
that face an uncertain future.
Realizing you have many papers to read I will be brief
with a few final points that must be raised:
Incomplete information was presented in the EIR/EIS
regarding the currents' effects on the discharge. Of particular
concern are the environmental impacts on the Carmel Bay, as its
already been designated as an Area of Special Biological
Significance ASBS), and the UCSC Marine Station.
On page 21 of the Draft EIR/EIS supplement it readss
"There is still the question... as to whether or not passing
112
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toxins through a biological process may alter the chemical
state and therefore detoxify some wastewater constituents.
This question has not been thoroughly addressed in the scien-
tific literature to date." We urge all necessary resources
be used towards answering this basic question before any final
decision is made regarding the Santa Cruz wastewater system.
Sulfur dioxide is mentioned as the means of dechlorination.
No mention was made as to the quantities necessary, or the chemical
or biological effects from its use.
Table 2-10 in the Brown and Caldwell Study does not list
plan 0D-RE7, but later in the chapter it was chosen as a reclama-
tion alternative chosen for detailed analysis. What basis of
selection did Brown and Caldwell use?
On page 25 of the Draft EIR/EIS supplement there is dis-
cussion of "an occasionally-surfacing waste plume," with the new
outfall. As we understand, the primary reason for the construction
of a new outfall line is eliminate the odor and visual problems
caused by the existing one. If the new outfall would adequately
take care of this problem it logically follows that there is no
need for this proposed $20 million project. The money and re-
sources would be better used to take care of the problem at
the source* at the treatment end.
Why should inland areas be penalized because they have no
ocean discharge,while coastal areas attempt to evade reasonable
standards and make the environment and recreational and the
fishing industry subsidize negligent industries.
In closingjI urge you to deny the waiver request and help
fund a reclamation program under the "new, innovative, or
113
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alternative" clause, bringing Federal funding in the amount
of 85^. If a waiver is necessary to achieve this condition,
grant one such a limited "basis as the San Diego and Monterey
areas are doing.
Thank you for your time and consideration- We anxiously
await your responses to our questions and statements addressed
in this paper.
cci REP
City of Santa Cruz
Santa Cruz City energy and Urban Services Task Group
NERC
EA
Sincerely*
114
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Ronald Pomerantz - Santa Cruz City Energy and Urban Services
Task Group
1. Alternative OD7 was not discussed in-depth in the Draft
EIS/EIR. It is not eligible for funding by EPA because
it does not provide secondary treatment. OD7 is a separate
alternative considered by the city and was therefore
not considered in the Draft EIS/EIR. Its potential
impacts, including estimated user costs, were presented
in a Supplement to the Draft EIR, prepared for the City
of Santa Cruz (Jones & Stokes Associates, Inc., 1979).
Anticipated rate increases for other project alternatives
ar£ listed in Table 7-7 (page 356) and discussed on
pages 358-360 of the Draft EIS/EIR (EPA and City of
Santa Cruz, 1979).
2. This subject matter is discussed in the "Supplemental
Analyses" section of this chapter (see page 180) .
3. While it is true that revenues from sale of reclaimed
water were not mentioned explicitly in either the
facilities plan (Brown and Caldwell, 1978c) or the Draft
EIS/EIR, these numbers were given consideration in com-
paring alternatives. Your figure of $160,000 income
for 5,000 acre-feet of reclaimed wastewater points out
the disparity between potential income and cost of pro-
duction. Brown and Caldwell estimated annual operation
and maintenance costs of approximately $940,000 for the
reclamation portion of Alternative OD/RE5^ (Brown and
Caldwell, pers. comm.). This does not include the annual
debt for the capital cost of reclamation facilities.
Your numbers indicate an income of $32 per acre-foot
while Brown and Caldwell predicts an operation and
maintenance cost of approximately $125 per acre-foot.
This is a relatively simplistic comparison, but it
points out that the cost of reclamation, as described
by Brown and Caldwell, makes the sale of reclaimed
water uncompetitive when compared to the costs of
existing water supplies.
4. The secondary implications of selecting a nonreclamation
alternative are discussed in the "Supplemental Analyses"
section of this chapter (page 191).
5. Use of aquaculture as an advanced treatment method
is discussed in the "Supplemental Analyses" section
of this chapter (page 186).
6. Industrial sewer service charges are not based solely
on water use rates. The city sewer rate ordinance re-
quires a charge of 3.2 cents per pound of suspended
solids contributed in excess of 300 mg/1 for high strength
115
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nonresidential discharges (Brown and Caldwell, 197 8c,
page 5-32). Clean Water Grant Program guidelines require
that charges be based on pollutant loading as well as
volume of flow. Some leeway is given to wastewater
treatment agencies, but revised charges in Santa Cruz
will probably take into consideration wastewater flows,
BOD load and suspended solids load. A monitoring program
will be developed to identify waste contributions and
pretreatment requirements will also likely be imposed
on those industries contributing unacceptably high levels
of toxic materials.
7. The source and relative contribution of potential toxic
materials entering the Santa Cruz waste stream has been
addressed in great detail in Santa Cruz's application
for modification of the secondary treatment requirement
under Section 301(h) of the Clean Water Act. This specific
pollutant source information was not developed in the
project report (Brown and Caldwell, 1978c) and therefore
was not discussed in the Draft EIS/EIR. However, the
influence of these industrial inputs was reflected in
the effluent quality data used to describe impacts of
the wastewater discharge. Any questions or concerns
regarding industrial sources of toxicants and their
influence on the Santa Cruz treatment plant should be
raised at the public hearings to be held on Santa Cruz1s
application for modification of the secondary treatment
requirement. The hearing dates have not yet been set.
8. Industrial pretreatment is discussed in detail in Santa
Cruz's Application for Modification of Requirements
of Secondary Treatment (Brown and Caldwell, 1979, Part E).
The city already has a pretreatment ordinance, but this
will be modified and strengthened before a Step 3 con-
struction grant is awarded in order to reduce toxic
pollutant loads reaching the treatment plant.
9. EPA has no specific quality requirements for ammonia,
chromium or arsenic in marine discharges. The California
Ocean Plan places limits on the concentration of these
elements in the receiving water after initial dilution
of an effluent plume. Calculations made by Brown and
Caldwell indicate that the design of a new outfall could
provide sufficient initial dilution to meet the receiving
water requirements (see pages 318-325 in the Draft EIS/EIR).
10. This topic is discussed in the "Supplemental Analyses"
section of this chapter (page 191).
116
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11. The high cost of reclamation alternatives developed
in the Brown and Caldwell (1978c) facilities plan makes
it extremely unlikely that an 85 percent "new or innovative
system" grant could be obtained from EPA. To date the
city has not pursued any of the reclamation options
considered in the Draft EIS/EIR, so the 85 percent funding
level is not being considered by EPA.
12. Existing and anticipated energy consumption for wastewater
treatment purposes was discussed on pages 348-349 of
the Draft EIS/EIR. The wastewater treatment numbers
were not compared to total city energy consumption,
as this was not deemed relevant to selection of a
facilities plan alternative. The implementation of
mitigation measures to reduce energy consumption is
of concern. On page 349 of the Draft EIS/EIR, several
mitigation® are mentioned. The City of Santa Cruz
has appointed an Energy Management Committee to closely
analyze the energy consumption patterns of city agencies.
This committee should be looked to for further specific
suggestions on how to reduce energy consumption at the
city treatment plant.
13. The Santa Cruz Department of Public Works undertook
modifications to the city landfill site leachate col-
lection system after the heavy rains of 1977-1978,
This included an increase in leachate retention and
pumpback capacity, isolation of runoff from the landfill
surface, and recontouring of the upper portions of the
landfill to direct runoff away from exposed fill areas.
The city feels these modifications should prevent leachate
from escaping below the landfill site in future rainy
periods.
Appendix P (pages 628-669) of the Draft EIS/EIR discusses
the economic and environmental implications of a variety
of sludge disposal alternatives for Santa Cruz. This
includes no action, but does not include vermiculture.
See page 180 in the "Supplemental Analyses" section of
this chapter for a discussion of vermiculture.
14. The distance between the proposed ocean outfall and
Carmel Bay is so great that there is virtually no possibility
that Santa Cruz wastewater could measurably affect the
ASBS. Appendix H of the Draft EIS/EIR characterizes
ocean currents in the vicinity of the proposed outfall
and in Monterey Bay in general. It also presents data
on dispersion of the waste plume under anticipated
oceanic conditions.
117
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15. Questions regarding the Supplement to the Draft EIR
(Jones & Stokes Associates, Inc., 1979) are responded
to in a separate Final EIR.
16. All of the ocean discharge alternatives would use sulphur
dioxide to reduce chlorine levels in the effluent. The
annual volume of consumption was listed in Table 6-7
(page 288) of the Draft EIS/EIR. Alternatives
0D- , 0°4g &nd OD^ would use 128 tons per year by T999.
There is currently no limitation or standard placed
on SO- levels in wastewater discharges. Typically S02
is rapidly converted to SO., in a well-oxygenated discnarge.
There have been no recorded adverse impacts from these
compounds in wastewater discharges.
17. Alternative OD/RE^ was unintentionally omitted from
Table 2-10 in- the facilities plan (Brown and Caldwell,
1978c). It was included in the original screening of
23 project alternatives (see Appendices J, K and L in
the Draft EIS/EIR).
18. Questions regarding the Supplement to the Draft EIR
(Jones & Stokes Associates, Inc., 1979) are responded
to in a separate Final EIR.
19. The U. S. Congress adopted amendments to the FWPCA
that allow coastal dischargers to apply for a modification
of the federal secondary treatment requirement. Modi-
fications will only be allowed if it can be proven that
lesser degrees of treatment can sufficiently protect
beneficial uses of the coastal waters.
118
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waiei'iree envmriiiiiiiiiiai ueailli
.1004 Ocean Street
Santa Cruz, Calif. 95060
zi
Dear persons at EPA
8/1U/79
Santa Cruz City needs more time to
develop a more appropriate wastewater
recycling plan/ reclaimation alternative*
The enclosed letter from Brown & Cald-
well stating that they would've develop-
reclaimatio alternatives for Santa Cm, had they more
time, is reason enough for the SW3CE to give our city more time in order to
prepare reclaimation projects that would omit the need for an outfall extension.
The County Community Resource Agency re-
port (77), The Watershed Study Plan, and the Growth Management Plan have not
been implemented yet, and as all of these suggest wastewater discharge, it is
apparant the lack of coordination between these studies and proposed outfall
extension, are undermining*
It is hopeful the EPA will see the 8
local community agenoies and 3 County Board of Supervisors (plus 2 City Council-
persons) dissatisfaction with the Brown & Caldwell Plan as enough to warrant our
Areawide Wastewater Facility Planning more tine*
Thank you
Billy Quealy
/f/r '
'.L '
{he
-------
CONSULTING kNGINEEFlS
BROWN AND CALDWELL
¦ r.O'S BY E. P. A.
REGION IX
GWM. CENTER
0 I "P
'« c; BAc*r n i r
n r vvilC'* >
j '
Am IB IU 39 AN'79
October 31, 1978
Mr. Wilson H. Fieberling
Director of 'Public Works.
City of Santa Cruz
809 Center Street
Santa Cruz, California 95060
266-30
Subject: Water Hyacinth Wastewater Treatment
Dear Mr. Fieberling:
You recently asked if we- had considered the use of ponds containing
water hyacinths as a wastewater treatment'alternative for Santa
Cruz when we prepared our recent proje'ct report.. This approach has
received considerable attention in recent years, due to the experi-
mental work being done by the National Aeronautics and Space
Administration in Bay Saint Louis, Mississippi.
The state guidelines.for preparation of project reports recognizes
that some of the treatment'alternatives which are identified nay he
readily dismissed based on professional judgment or preliminary
cost estimates. Some of these alternatives are discussed starting
o"*page- o-ji or 'the project report; although not. discussed therein,
the use "of water hyacinths also falls into this catagory.
One of the major reasons the use of water'hyacinths was not seri-
ously considered is that the State Water Resources Control Board
(SWRCB) has rafused •to grant Such a project other tnan on a pilo-fc
study basis. The tight time schedule imposed on the City ot Santa
Cruz by the Regional Water Quality'Control Board pronioits . the
enployment of a time consuming pilot study. The SWRCB's position
is well taken since the water hyacinth flourishes in '-the warm,
somi-tropical climate of the southeast United States (principally
Louisiana and Florida). . The behavior and productivity of these
plants would be subject to question in the cooler marine climate
of Santa Cruz, and if they are to take a role in protecting public
health, their- effectiveness must be analyzed.
BPQWN AND CALOWtL. 1501 NOB T"- BROADWAY WALNUT CREEK CA UlSt'n." ??10
vv.\i»iuw;ntfc* IV,'V Ar-nrjA f.L'GFiUE SfeM'l l: 111' ¦ ' I V"
120
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J d f tj ccOLLj /) f/Vl 1 s ©
, 7 ! *
In Orange Grove, Mississippi, a' 0.7 acre hyacinth pond is being £
used to treat 0.5 mgd of domestic sewage. If this loading rate
could be assumed for Santa Cruz (which is probably optimistic due
to differing climates), approximately 30 acres of ponds would be -
required to treat the 1999 ADWF of 21 mgd. Additional land would '•* J
be required for berms, service roads, harvesting equipment, and ") KjU. \
methane production and storage. Obviously, such .an operation ^
would have to be located elsewhere than in Neary1 s Lagoon. The ^
lagoon itself could not be used because the prodigious growth of
the hyacinths would soon choke out the lagoon even in Santa Cruz's
paring.,. 1 ^ mnt-e. They const f£"ut e "a gr e a t"" n uls ance "i~n" the^'w at eT%7a y s
of Louisiana and Florida.
Under favorable conditions, one acre of water hyacinths can produce
over 70 tons of dry plant material annually (Yount, J. L., 1964,
"Report of the 35th Annual Meeting, Florida Anti-Mosquito
Association," Page 83). Even under Santa Cruz's less favorable
conditions, it is obvious that the plant material must be routinely
harvested. Direct disposal of this material is infeasible, and it
probably could not be used for animal feed because of the large
amounts of energy required to dry it, and due to the presence of
heavy metals such as chromium which are concentrated in the plant
material.
It is possible to anaerobically digest the harvested plants to
produce methane as an alternative energy source. Disposal of
sludge from the digestion process would still be a problem. The
operations and maintenance costs required to harvest and process
the hyacinths; produce, scrub, store and distribute the methane;
and dispose of the resulting sludge are beyond the scope of this
letter, but they would be sizeable.
In summary, we dismissed the use of water hyacinths as a viable
treatment alternative because it is presently an essentially
experimental process' limited to warm* climates; it forced the
abandonment of the existing, recently expanded facilities at
TTeary's Lagoon; it. is probabl^_not cost-ef fective; and it is not
'immediately eligible jfor^grang^runaing.
Mr. Wilson H. Fieberling
October 31, 1978
Page two
BBOWN AND CALDWELL 1501 NORTH BWQAOWAY WALNUT CPEEK Q 9*596 (415) 937-0010
ENVIRONMENTAL SCIENCE ANO ENGINEERING WALNUT CREEK PASADENA EUGENE SEATTLE HTr-C'l
121
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Mr. Wilson H. Fi.eberli.ng
October 31, 19-78
Page three
We would be pleased to discuss this matter further with you. If
you have questions or need additional information, please do not
hesitate to call.
Very truly yours,
BROWN AND CALDWELL
Robert L. Mil 13
Associate Project Manager
RLM:rs
cc: Mike Rushton, Jones & Stokes Associates, Inc.
bcc: R.. Cooley
R. Hunter
D. Parker
AMD CALO'.veU- 1501 north RnoAOWA'' V.AuNi^r C"EE" .¦ •• .o
tNvincivt^m sctNcr Jfi'J r'ic.i'iiisofi'-, vmi.mi.it fi>cr« t.r.fiir ;emu' :>
122
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Billy Quealy
1. If the City of Santa Cruz decides that it wants more work
to be done toward a wastewater reclamation alternative,
this desire should be expressed to the SWRCB and the RWQCB.
The RWQCB is the agency charged with enforcing the waste-
water improvements timetable of compliance stated in the
city's NPDES permit. To date the city has indicated no
desire to further pursue a reclamation alternative. Santa
Cruz has, in fact, made application for a modification of
its secondary treatment requirement so that it can continue
with primary treatment and ocean discharge.
123
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{|4£--IS4] 3
r o;o#>; i%
Jul y 13 , 1979 -'7Q
. ^ : i I o
EPA
Region 9
215 Freemont Street
San Francisco, Calif. 94105
To Whom It May Concern:
RE: Santa Cruz Areawide Wastewater Facilities Plan
Now that your EIR has been completed on the Santa Cruz Weary's
Lagoon outfall design and construction, I would like to express
my analysis, generally.
As to the concept of a new outfall "upgrading- the wastewater
disposal system-well, sweeping the problem under the rug would
be closer to the truth. Whether this outfall shoots nutrients,
and probably industrial toxins, to the ocean after primary or
secondary treatment seems of little significance, compared to the
true impact of this non-cyclic approach.
The way we use heavy metals, such as chromium, besides increasing
the chance of toxifying the local biologic systems, depletes these
materials reserves, and as you should know will not last that much
longer historically.
As for phosphorus-what are the environmental effects of contin-
uously supplying Florida's mined phosphates to Santa Cruz agri-
culture, both from the standpoint of the environmental impact of
mining wastes in that region, some of it being radioactive material ,
and the long term energetics of the transport of such fertilizer
from such a distance, while ignoring phosphorus "wastes' in our own
backyard?
And at a time the nation searches in desperation for energy, the
outfall plan ignores the potential of photo synthetically produced
biofuel and it's fertilizer rich by product, as a reward for clean-
ing our water and recovering nutrients.
I was outraged to hear the simplistic half truths and at times out-
right incorrect statements made by the Brown and Caldwell expert,
particularly in regard to aquatic plants as tertiary treatment of
wastewater, and City Public Works before the City Council approved
a waiver from even secondary treatment, and thus pave the way for
the Brown and Caldwell pipe dream, or outfall, if you will.
And when they complete this twenty-one million gallon monstrosity,
where are they to get the additional water to flush through it?
Build the Zayante Dam, I suppose.
124
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The new outfall, if built, will not only allow this region to
avoid necessary stewardship of its finite water resources and
build new housing developments in areas that should be conserved
for the long term health of this region, such as in Scotts Valley's
case, which by hooking to the Santa Cruz outfall can continue
growth in areas that should be used for sludge and wastewater re-
clamation and possibly, as in the case of San Francisco's Golden
Gate Park and Santee California, for recreation, as well.
For the price of the new outfall and secondary treatment facili-
ties we could be well on the way to tertiary quality water through
biological systems ranging from more decentralized enclosed or
semi-closed lagoons featuring aquatic plants (which Brown and
Caldwell did not consider for us) to orchards and tree gardens in
our voter approved greenbelt, and other uses or the disposal of
bio-tertiary quality water through the present outfall until a
demand for it occurs.
It is my opinion that EPA should either be prepared to find ad-
ditional capital to help undo the damage of this myopic outfall
planning along with the other involved powers that be in the not
too distant future, or save the capital for this new outfall un-
til we can get the proper bio-tertiary sewage plants funded and
providing relief from inflationary linear flows.
Sincerely yours,
Tony Ryals
9*00 3-
Tony Ryals
875 Fanning
Ben Lomond,
Grade
Calif. 95005
125
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Tory Ryalt
875 Fanning Grade
Bsn Lomond, Ca. 93005
-DEAR KR JCRLING ,
I AM A MEMBER CF A LOCAL WASTEWATER STUTY GROUP,
NUTRIENT ENERGY RESOURCE COMMITTE?, HERE IN THE SANTA
CRUZ, CALIFORNIA AREA.
OUR 3 MOST CRITICAL CONCERNS AT PRESENT, WHICH
WERE EXPRESSED AT THE LOCAL EPA DRAFT EIR/EIS HEARING,
ARE I) THE EN71CJRNMENTAL AND ECONOMIC IMPACTS OF
OBTAINING NEW SOURCES OF WATER TO REPLACE THE UNCLAIMED
WATER BEING THROWN TO THE . OCEAN THROUGH SC WASTEWATER
FACILITY FLAN'S PROPOSED LONGER, LARGER OUTFALL.
2) THE USE OF CHLORINE, PARTICULARLY AFTER PRIMARY
TREATMENT AND THE FRODUCTICN AND DISPOSAL PROBLEMS OF
CHLORINATED HYDROCARBONS THIS TECHNOLOGY GENERATES.
OZONE OR AT MOST ANYTHING ELSE IS PREFERABLE.
3) MOST IMPORTANT . . .
lb TO H/.VF- T£E EFA OFFICIALLY ACENCWLEDC-E THE CONNECTION
BETWEEN OUR FRCPOSED OUTFALL, AND THE ENVIORNMENTAL IMPACTS
OF FRESENT FERTILIZER OPERATIONS, SUCH AS THE FLORIDA PHOS-
PHATE MINES AND ITS RADIOACTIVE SLAG WASTE, ETC.
THIS WE WOULD EXPECT TO EE IN THE EPA'S FINAL EIR/
EIS STATEMENT.
126
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WHILE WE ENCOURAGE THE PRODUCTION OF HI0FUELS IN
THE U.S., WE RECOGNIZE THAT TRET CAN NEVER SIGNIFICANTLY
CONTRIBUTE TO OUR ENERGY PICTURES' FUTURE UNLESS THE ESS-
ENTIAL PLANT NUTRIENTS WITHIN OUR SEW • AGE ARE RECLAIMED,
WHICH IS NOT THE CASE FCR PRIMARY OR SECONDARY TREATMENT
ALONE•
! PLEASE INFORM US & EFA/SF, SO WE ARE ASSURED, THROUGH NEPA
t
AND EPA POLICY, THE FERTILIZER MINING OPERATIONS WILL BE
LISTED IN THE EFA'S FINAL EIR STATEMENT FOR THE SANTA CSUZ
AREAWIDE WASTEWATER FACILITY PLAN.
I
! THANK YOU
" TONY RIALS
RE*. GRANT § C-06-1006 BILL HELFHINGSTIEN L PAUL DEFAICO
EPA-9-CA SANTA CRUZ £pA reqjqn jj 215 HIEMONT ST.
WWTP-79
SAN JRANCISCO, CA. 9U05
,B3/ TR 30/2/79
-------
Tony Ryals
1. It is impractical to expect the Santa Cruz facilities
plan EIS/EIR to analyze such far-reaching secondary
implications as its role in the interstate transfer
of chemical fertilizers. While you raise a valid point
that present patterns of transferring resources and
products from one part of the country to another are
not energy-efficient, EPA cannot expect each local
jurisdiction to address these national-scale issues
in the process of planning for local wastewater facilities
improvements. Your mention of such topics, however,
will make local Santa Cruz decision makers more aware
of the broader implications of their actions.
2. This topic is discussed in the "Supplemental Analyses"
section of this chapter (page 186).
3. An extended ocean outfall will be needed regardless of
the level of treatment selected by Santa Cruz. Even with
advanced treatment and reclamation, winter flows will have
to be accommodated. Unless the reclamation scheme could
provide enough storage for all winter flows (an extremely
large acreage would be required), some winter discharge
to the ocean would be necessary. The terminus of the
present outfall is not adequate to meet revised State
Ocean Plan water quality standards.
It should be noted that in the opinion of some members
of the scientific community, the discharge of primary
treated effluent to the open ocean is beneficial in that
it provides a readily usable source of nutrients to
marine biota.
128
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SHELTER
LAGOON
SHELTER LAGOON ASSOCIATION
100 Shelter Lagoon Drive
Santa Cruz, Ca. 95060
August 27 , 1979
U. S. Environmental Protection Agency
Attn: Hearing Office, HE-154 Region IX
215 Fremont Street
San Francisco, Ca 94105
City of Santa Cruz
City Hall
Santa Cruz, Ca 95060
The Shelter Lagoon Homeowners Association represents ninty-
five (95) home owners whose homes front upon Neary's Lagoon
across from the City's sewage treatment plant. The '
comments and statements in this letter and its attachment
constitute the view of these homeowners.
These comments are intended for public hearings to be
held on August 29, 1979, and for incorporation into the
final EIS and EIR.
We wish to express our concern for what we consider to be
a grave deficiency in the EIS/EIR - namely its failure to
identify and specifically measure the anticipated impacts
of proposed substantial enlargements of the existing
sewage treatment plant - upon the residents of the hundreds
of nearby housing units within the City of Santa Cruz.
Furthermore, the Report does not deal, in any but the most
superficial way, with mitigation measures that might protect
these existing residential areas surrounding the treatment
plant - in the event that substantial enlargement of the
plant were to be selected as the alternative for dealing
with regional wastewater problems. These nearby housing
units and this entire recreational area constitute a major
regional resource deserving greater consideration than that
expressed in the documents.
It is our recommendation and request that additional study
be undertaken to correct these major deficiencies. Such
additional study should include but not be limited to the
following: CI) maps showing the location of the various
Neary's Lagoon treatment plant expansions in relation to
the surrounding residences - together with distances to
residences; (2J present and anticipated noise and odor
measurement in quantitative terms for each alternative
(including OD7) insofar as these would impact on the
residences in the area; and on the entire City; (3) elevations
of the proposed treatment plant structures so that the visual
impacts upon the surrounding areas can be measured; (4)
descriptions of specific mitigation measures that mieht h
employed to make the plant compatible with the City and tJL
nearby residential area. 12g
-------
With respect to the alternatives, our Homeowners Association
favors relocating the treatment plant to the "west site" so
that a new regional facility is not imposed upon this
sensitive residential and recreational area within the City
of Santa Cruz. We feel that it is just good common sense
that a new regional facility with more complex secondary
treatment capabilities and the potential to "go wrong" from
time to time should be placed well away from existing
residential and recreational areas.
Our second choice would be to limit plant expansion on the
present site to primary treatment in accordance with
alternative 0D7 - provided it is understood that any future
substantial enlargement in size or process would involve
plant relocation to a non-urban area.
SHELTER LAGOON HOMEOWNERS ASSOCIATION
/
¦' /"' * /
Robert S. Lawrence
Representative
RSL:jb
130
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Shelter Lagoon Homeowners Association
Comments upon EIS/EIR
Santa Cruz Wastewater Facilities Plan
August 1979
The Chapter 1 Report Summary does not give adequate regard
to the impact on adjacent residential uses. The following
additions are recommended:
p. 10 add to "Alternative OD1." the following:
"During construction,use of the adjacent recreation
facilities will be adversely impacted and the noise,
dust and construction activity including construction
traffic will affect the nearby residents. Modification
of dikes may destroy vegetation recently planted to
screen the existing facilities from view."
p. 13 Add to the second paragraph on this page the
following:
"AlternativesODl and OD/RE5 would have a long term
adverse affect on people residing in this area.
Treatment plant activities would be brought into closer
proximity to residences."
p. 13 Modify the third paragraph to read:
" All of the alternatives (except non-project) would have
a significant impact on land uses. Some of the
implication nn arw1 <">n/PF. mentioned above. In
influence adjacent residents. Occasional odor problems
have been associated with plant operation in the past;
these may continue in spite of operation and equipment
improvements. At ultimate expansion there would be
three additionaT~round digester plants visible . Treat-
ment tanks would be increased sudstantially. Alternative
0D4B would have tKe beneficial impact of "removing the
sewage treatment plant from a residential area. Three
of the proposednew treatmant plants will displace
agricultural land uses (OD.g OD/REr tertiary plant site,
and OD/RE7 Watsonville plarit'expansion). Once these plants
are put into operation their impact on existing and
planned adjacent land uses should be minimal. The long-
term use of wastewater for crop irrigation proposed in
OD/REr could adversely affect the viability of soils
in the Pajaro Valley and require costly changes in
farming practices. Crop marketability could also be
adversely affected. In contrast, the new water source
could prolong the viability of farming in areas that
are currently facing a rapid deterioration in the quality
of existing groundwater supplies. The nutrients in the
wastewater could also have some value as a source of
addition,
would continue to
131
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fertilizer. These potential impacts on agricultural
land use are not completely predictable with present
information. A pilot wastewater irrigation project
being conducted in the Salinas Valley by the Monterey
Peninsula Water Pollution Control Agency is studying
these same problems. The progress of this study should
be closely followed so that the potential problems
with wastewater irrigation can be anticipated and
avoided in Santa Cruz County."
It is noted that operation and equipment improvements
are referred to with the suggestion that these will
mitigate odors - such improvements do not seem to be
mentioned in chapters 6 or 7. In fact, on p. 350,
paragraph 1 suggests that these impacts will not
be mitigated by the new facility.
p. 19 Add the following under "Operation Impacts":
Aesthetics and Effect on Nearby Residents
o Relocate treatment plant to non residential area
o Effectively landscape facilities from residential
areas, employing a high leval of landscape maintenance,
o Extend high berm around all plant facilities,
o Acoustically baffle plant noise
o Color plant facilities to blend into the environment,
o Employ treatment processes which are most effective
in controlling odors.
p. 202 This map shows the Shelter Lagoon townhomes as
apartments. This is not accurate and the map should
be modified.
Chapter 6
The alternative projects should be mapped showing
proximity to surrounding land uses.
132
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Shelter Lagoon Association
1. The impacts of constructing and operating new wastewater
facilities in Nearys Lagoon are discussed at several points
in Chapter 7 of the Draft EIS/EIR. These discussions
include a consideration of impacts on adjacent residential
and recreational land uses. Table 7-1 in the Draft EIS/
EIR summarizes potential construction impacts and mitigations.
The potential for odor impacts is discussed on pages 333-
334; aesthetic impacts are discussed on page 350, noise
impacts are included on pages 352-353. Each of these impact
discussions includes some type of potential mitigation.
Figure 6-3 to 6-6 (pages 264-268) in the Draft EIS/EIR
show the relationship of proposed new treatment facilities
to residences surrounding Nearys Lagoon. Figure 4-2 also
shows the relationship of existing wastewater facilities
to adjacent land uses. This figure includes a linear
scale for estimating distances. Figure 4-2 has been
modified and included herein as Figure 1 to show the
relationship of adjacent land uses to the treatment plant
expansion planned under Alternative ODia*
Odors cannot be readily quantified. There has been no
attempt to measure them at Nearys Lagoon. However, odors
should not be increased as a result of the improvements
planned for Nearys Lagoon under Alternative ODi^, if
facilities are properly operated. (Alternative 0D1A is the
secondary treatment alternative being pursued by Santa
Cruz. Alternative OD7 is not discussed in this report.)
Secondary sedimentation tanks and sludge centrifuges are
to be covered for odor control. The city should establish
a means of monitoring treatment-related odors so that
problems can be readily detected and corrected should
they ever occur. If the treatment plant should malfunction
or suffer a power outage, the chance of a serious short-
term odor problem will still exist. A back-up power
generator is available if a power outage should
occur, but a process malfunction can only be avoided
by careful operation and maintenance of the plant.
Noise levels in the immediate vicinity of the existing
treatment facilities were measured by Brown and Caldwell.
Levels recorded adjacent to the treatment facilities
themselves ranged from less than 50. to about 65 dB.
Measurements taken on the berm surrounding the plant
ranged from less than 50 to 55 dB when wind was not gusting.
Recordings made in close proximity to roadways reached
as high as 72 dB when trucks passed. Numerous visits
to the Nearys Lagoon park area indicated that automobile
traffic on adjacent roads is by far the most noticeable
source of noise in the park.
133
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FIGURE 1
RELATIONSHIP OF ALTERNATIVE OD1A TREATMENT
PLANT EXPANSIONS TO ADJACENT LAND USES
-LEGENDS
SINGLE FAMILY
APARTMENTS
DUPLEX
TRANSIENT LODGING/MOBILE HOMES
COMMERCIAL
HHIII TRANSPORTATION/COMMUNICATIONS/UTILITIES
PUBLIC ASSEMBLY - CHURCHES
GOVERNMENT LAND
MANUFACTURING
VACANT
EH
CD
A
FT
n
500
1000
FEET
PLANNING AREA N>
DOWNTOWN SOUTH OF LINCOLN
Bose From The City Of Santa Cruz
Plonning Dept.; Land Use From Dec. 1975
Plonning Dept. Land Use Mop.
WASTEWATER TREATMENT
PLANT SITE
-------
Estimates of future noise levels are only speculative,
as this will depend primarily on the acoustic efficiency
of structures constructed to house new wastewater facilities.
The oxygen generation unit originally proposed for
Alternative 0D^A appears to pose the greatest threat
of a noise increase. However, Brown and Caldwell indicates
that housings now being used are capable of reducing
noise levels to 55 dB adjacent to these units. This and
the other plant additions planned under Alternative
are not expected to raise ambient noise levels outside the
berm beyond 60 dB. All new pumps and motors will be
housed in structures to minimize their noise impact.
Elevations made for Alternatives OD^a an^ ODib by Brown
and Caldwell are included as Figures 2 and 3.
Specific mitigation measures are included in the Draft
EIS/EIR. A summary of these potential measures is
presented below:
Odor Reduction
1. Enclose secondary sedimentation tanks and sludge
centrifuges (Alternative 0D^A).
2. Ensure that all existing and new facilities are
properly maintained, including all odor control
equipment.
3. Establish a means of monitoring plant odor pro-
duction so that any off-site impacts can be
rapidly detected and corrective action can be
taken.
4. Relocate wastewater treatment facilities outside
of Nearys Lagoon.
Noise Reduction
1. Enclose all new pumps, motors and oxygen generation
facilities (Alternative ODia) in acoustically designed
structures.
2. Maintain a berm around all treatment facilities.
3. Vibration-isolate pumps and motors; install acoustical
filters in pumps.
4. Relocate wastewater treatment facilities outside
of Nearys Lagoon.
Aesthetics
1. Maintain a berm around all treatment facilities.
2. Employ pressure swing-type oxygen generation
equipment (Alternative ODia) to avoid construction
of the cryogenic system tower.
3. Maintain all facilities within existing berm or
relocate facilities outside of Nearys Lagoon.
135
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2. The additions you have suggested appear to be appropriate.
3. See Response Number 1 for a response to this comment.
It lists mitigation measures for odor problems.
4. These additions appear to be appropriate.
5. A revised map has not been included herein, but the
correction is appreciated and duly noted.
6. Figures 6-3 to 6-6 and 4-2 in the Draft EIS/EIR show the
relationship of wastewater facilities to adjacent land
uses.
136
-------
FIGURE 2
ALTERNATIVE 0DtA
1A
SITE CROSS SECTIONS
SOURCE1 BROWN & CALDWELL, 1978c
137
-------
FIGURE 3
ALTERNATIVE 0D1B
SITE CROSS SECTIONS
60
| 40
z
o
<
>
20
v WW
AERATION TANKS
HORIZONTAL SCALE IN FEET
0 50 100 150 200
SOUTHERN
PACIFIC
RAILROAD
imrr
SECONDARY SEDIMENTATION
TANKS
SECTION A
60
40
z
o
t 20
>
ui
_j
UJ
SOUTHERN
PACIFIC
RAILROAD
AERATION
TANKS
BLOWER
BUILDING-
i
i
i
'/¦'f: \ •¦'%•////
'/// '
>k\
"" \
'rrr^i
PRIMARY SEDIMENTATION I
TANKS (EXISTING)
\
NOTES: 1. CUTS ON FIG. 8-27
2. PILES NOT SHOWN
\ 1
\ '
4
w\
A
. i
SECONDARY
1SEDIMENTAT1ON
I TANKS
SECTION B
SOURCE- BROWN £ CALDWELL, 1978c
138
-------
August 29, 1979
U. S. Environmental Protection Agency
Attn: Hearing Office, HE-154 Region IX
215 Fremont Street
San Francisco, Ca 94105
City of Santa Cruz
City Hall
Santa Cruz, Ca 95060
Re: Neary Lagoon Sewage Treatment Plant
We developed and now manage Cypress Point Apartments, a
240 unit apartment complex housing some 387 people, located
about 1,500 feet from the sewage plant.
The complex is the largest in Santa Cruz and beautifully
located in the sheltered Neary's Lagoon basin. Unfortunately
also nestled in the lagoon basin with us is the sewage
treatment plant. On occasion we do detect a very distinct
sewage treatment smell. We all accept the present plant,
as it was there first and that's the trade-off to living in
such a special place. Our residents find the peacefulness
and serenity of a walk around the lagoon most difficult to
put into words.
Now we understand that the size of the sewage plant may be
increased and the sewage may be kept in the lagoon basin
longer for advanced processing. We also understand that
one proposal would move the plant and future expansion west
of town.
In that Neary's Lagoon is such a special place, right in
the heart of Santa Cruz we urge you to consider the plant
site proposed west of town. We've lived with the lagoon
for nine years now and wish you could experience what we're
feeling by spending some time in the lagoon basin.
1265 Montecito Avenue Suite 100 Mountain View, CA 94043 (415)969-7722
139
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1. If it's decided not to move the plant we urge you not to
pump additional sewage from other areas into the lagoon plant.
If you have to pump all of the sewage to Neary Lagoon,
then we urge you not to keep it for the smelly additional
processing, but pump it on with only primary treatment.
Not much has been mentioned about the people living near the
lagoon treatment plant and I hope that they are not totally
over looked.
Sincerely,
THRUST IV MANAGEMENT CORPORATION
Gordon E. Call
President
GEC: jb
140
-------
Thrust IV
1. The expression of your concern is appreciated. As noted
elsewhere in this Final EIS/EIR, the city is currently
pursuing a modification of the secondary treatment
requirement so that it can continue with primary
treatment and ocean discharge of effluent. This
approach would not significantly affect adjacent
residents. If secondary treatment is installed in
Nearys Lagoon, there should be no appreciable increase
in odor problems if all equipment is operated properly.
141
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<£C'0 BY E.P.A.
region IX
COMM.CENTER
Sep II U 52 RH '73
Environmental-Protection Agency
215 Freemont St.
San Francisco, CA. 94105
Jane T. Weed
Energy Action of Santa Cruz
P.O.Box 1580
Santa Cruz, CA. 950^0
September 9»1979
Dear Friend;
The following three pages are testimony given before the EPA in
Santa Cruz on August 29, 1979. The hearing was in regard to the proposed
waiver and plans for waste treatment facility upgrading in Santa Cruz, the
case was referred to as HE 1^4. Please incorporate this testimony into the
compilation of testimony given that night.
Our organization would like to be kept informed on developments pertaining
to this topic and can be reached at the above address or by telephone:(4o8)
462-04l4. Thank-you very much for the attention you are giving this matter.
Sincerely
cc: Energy Action
Nutrient Energy Resource Committee
JTW & Ronald Pomerantz
Gity of Santa Cruz
142
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G-oodevening, my name is Jane Weed and I live at 509 Seaside St.
I am with Energy Action of Santa Cruz. We are a private, nonprofit,
research organization that has been funded by a grant from the Calif.
State Energy Commission to assess Santa Cruz County resource potential
and energy use profiles. We are also developing plans whereby local
government, business, industry, and labor can implement orograms
for county energy self-sufficiency. This brings me here tonite? to
respond to the EI.i.
Santa Cruz government officials, large engineering and consulting
firms and many local citizens view sewage treatment as something to deal
with, to inject with chemicals, and pump it away, (and in xhis case-)
to dump it in the ocean...'out of sight, out of mind1, except for
the ever increasing costs of energy, chemicals, and furtner sophis-
ticated technologies to isolate us from our secretions. I would like
to point out that there are alternatives.
Historically, sewage and waste water have been valuable resources
for societies. Especially todaywhen the costs of nonrenewable fuels
are rising so tremendously we must plan now for the future and for
efficient, economic utilization of our resources. Sewage must be
seen as a resource to utilize, not a problem to deal with.
Let's set the stage...here are some examples:
In Asian countries sewage has been used for fertilizers and methane
generation for centuries. In the last five years China has built
3 million Bio-gas plants using human and animal waste for fuel pro-
duction. Using a resource readily available, they are minimizing their
dependence on scarce, expensive, nonrenewable fuels. For every
pound of organic waste that goes into the Go-Bar plants, they get
one cubic foot of bio-gas (natural gas) with remaining residues used
as fertilizers. Here again alleviating the need for costly and
environmentally dangerous chemical fertilizers which are predominantly
made from petroluem#
In La Mar, Colorado the municiple government is now engaged in the
construction of a waste reclamation plant that would recover methane
gas, a*!d nutrients from municiple, agriclutural and animal wastes.
According to Director of Public Works, Bill Carnahan, it has turned
a traditionally money loosing operation such as sewage treatment into
an environmentally sound, cost effective venture that is benifitting the
entire oommunity,
143
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Now here in Santa Cruz County if we were to follow the models of La Mar
Colorado and the Go-Bar Gas facilities of China and given the existing figures
for Santa Cruz, we could utilize the approximate 80 tons of organic influent
that will ultimately enter the Santa Cruz system on a daily basis and through
aneorobic: digestion, receiver close to 150,000 cubic feet of biogas or methane,
more than enough to supply the energy needs of the current facility not to mention
the recovery potential for fertilizer which the county could intern sell to local
farmers or use as a revenue produci^n export product. By Energy Action's est-
imate the fertilizer could have a nutrient content ratio of approximately 7%
hi
Nitrogen, ibft Phosphorus and 12% Potassium, a rich mixture^'agri cultural standards.
Given the cost of energy for the operation of an advanced primary treatment
system and Brown and Qaldwells predictions that the cost of energy will increase
10 fold to 31.5 million per year by 1997 (thus far out-pacing the current rate
of inflation), Santa Cruz can ill afford to overlook to cost effective potential
of a methane and nutrient recovery system instead of leaping into a technical
fix.
3he alternatives detailed in the EIR by Brown and Caldwell may promise
rate payers both questionably adequate treatment facilities to pay for but
also increasing prices just to maintain and operate them. Ihis is economically
imprudent.
It is our conclusion that the benefit cost analysis of the Brown & Caldwell
study did not thoroughly explore and compare the various sewage treatment
options, as they did not consider the possibility of an economically self-
sustaining treatment operation- a hybrid of alternatives.
Historically water shortages in Santa Cruz County have posed very serious
dilemnas to agriculture, industry and homeowners. At the current time the over-
draft of water in the Pajaro Valley is so severe that farmers are now experieeing
dangerous levels of salt-water intrusion into the valuable fresh water aquafirs
so needed in that region for irrigation. At the same time plans exist to spend
-2-
Weed
144
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anywhere from ^25-§50 million to construct the Zayante dam to impound water.
Given that the waste treatment facility in Santa Cruz will expell between
10 and 15 million gallons /day it seems imprudent to spend such exorbitant
sums on additional water resources while there are such vast possibilities for
waste water reclamation. Not only is it possible to utilize this otherwise
wasted resource for agricultural and parkland irrigation, groundwater recharge
and industrial processes, we can also avoid the economic drain and environmental
devastation caused by such proposed dam and resevoir projects as Zayante.
Qice again, we can question whether the consulting firms looked carefully
at such secondary environmental imis^pcts as Zayante Dam, and whether or not they
considered the water resource potential available from the current and proposed
treatment system as a means to offset the water supply defecit of the Santa
Cruz Bio-region.
Though it is not common practice for the engineering and consultative
firms to view sewage treatment with in the confines of a closed, ecological
and economic cycle, we are of the mind that any study must utilize a wholistic
approach inorder to obtain accurate and relevant conclusions. Prom our
analysis the consultant's study failed to consider these parameters thus we have
determined that it is incomplete and ultimately unacceptable.
Energy Action of Santa Cruz is willing to offer its services to both
the Environmental Protection Agency and Santa Cruz City and County to devel-
ope a sewage treatment plan which will truly meet the needs of our community.
Thank-you very much for this opertunity to speak.
Jane T. Weed
Energy Action of Santa Cruz
P.O.Box 1380
Santa Cruz, CA. 95060
(408) 462-04l4
-5-
145
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Jane T. Weed - Energy Action of Santa Cruz
1. Brown and Caldwell conducted a thorough sludge reuse
analysis for the city as part of the facilities planning
process. An impact analysis of their alternatives is
presented in Appendix P of the Draft EIS/EIR. As a
result, Brown and Caldwell has recommended continuing
the present mode of sludge disposal as the most cost-
effective (dewatering and landfilling). This direction
is being followed with the knowledge that current energy
sources may become extremely expensive. The wastewater
facilities constructed under Alternative ODi& or OD7
would not preclude future use of sludge for gas
generation and fertilizer.
2. The facilities planning work considered a full range of
project alternatives, including a number of reclamation
possibilities. The conclusion of the analysis was that
there was not sufficient market for reclaimed wastewater
in the Santa Cruz area to use all of the expected effluent.
Only the Pajaro Valley offered a large enough market.
The cost of treating and transporting water that great
distance proved to be unacceptably high in the opinion
of the City of Santa Cruz. Direct groundwater recharge
was not considered because of the strict treatment require-
ments likely to be imposed and the potential public health
risks.
3. This subject is discussed in the "Supplemental Analyses"
section of this chapter (page 191).
146
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Response to Oral Comments
The following section presents oral testimony given
at the Draft EIS/EIR public hearing and provides responses
to comments. Only those parts of the oral testimony requiring
some response are included. A complete version of the public
hearing record is attached at the back of this document as
Appendix A.
A separate subsection has been provided for each commentor.
Those portions of a person's testimony that require some
response are first presented, with numbers in the left-hand
margin to indicate specific comments. This testimony is
followed by appropriately numbered responses. Comments are pre-
sented in the order that they were presented at the public hearing
If specific questions have already been responded to in the
Written Comments section, the reader will be referred to
that section.
D. L. Cleveland
Comments. I would be opposed to any extension of the
present plant. We are getting by the way it is. It isn't
too obnoxious> but we would certainly be objected -- we would
certainly object to any further expansion there.
There was one point that was not brought up} and that
was the possibility of staying there with your first primary
treatment and then moving up in the West Site for just the
secondary treatment.
I would question Mr. Mills on one statement that he made
about the possibility of oil and things out in the water.
A properly designed and operated secondary treatment plant
would never allow any oil to get out into the ocean.
Responses. The specific split-plant alternative you mention
was considered briefly in the Project Report (Brown and Caldwell,
1978c, page 8-56). This option was dropped because it posed
operational and maintenance difficulties and inefficiencies
and has a higher cost than Alternative ODi. if new facilities
were to be constructed on the west side of Santa Cruz so
that impacts on the Nearys Lagoon area could be avoided,
it would probably be more appropriate to remove all treatment
facilities from Nearys Lagoon.
Secondary treated wastewater effluent characteristically
contains small amounts of oil and grease. This may come
from household sources or industrial sources. The revised
State Ocean Plan allows a monthly average effluent concentra-
tion of 25 milligrams per liter (mg/1) grease and oil.
147
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Norman S. Lezin
No response required
Bill Bahn
No response required.
William Paiss
Comment, s. This kind of linear flow from mines to fields
to ocean has had a tremendous effect in areas we are not
usually aware. For example, in the years since World War
II, the production of fertilizer nitrogen has increased 25
times over food production over the same time. Treatment
methods of the kind which Brown and Caldwell suggest and
the Draft EIS/EIR condone will only increase this trend and
make problems worse.
Many of the speakers giving testimony this evening will
not he disagreeing with the content of the original study
or to the EIS/EIR but, instead, to its limitations and
exclusions. I would like to comment on one treatment method
not included in any of the planning studies. It does not
require high technology, large quantities of chemicals, and
is less expensive than conventional systems. When Brown
and Caldwell were asked why they did not include this kind
of treatment in their studies, their reply to Mr. Fieberling,
Director of Public Works, was the following. I will only
read a very small portion of this letter.
"One of the major reasons the use of water hyacinths
was not seriously considered is that the State Water Resources
Control Board has refused to grant such a project other than
on a pilot study basis. The tight time schedule imposed
on the City of Santa Cruz by the Regional Water Quality Control
Board prohibits the employment of a time-consuming pilot
study. The SWRCB's position is well taken since the water
hyacinth flourishes in the warm, semitropical climate of
the southeast United States, principally Louisiana and Florida.
The behavior and productivity of the plants would be subject
to question in the cooler marine climate of Santa Cruz, and
if they are to take a role in protecting public health, their
effectiveness must be analyzed."
148
-------
I have before me another letter from a firm called Solar
Aquasystems 3 Incorporated, who specialize in wastewater reclama-
tion by controlled environment3 ecological process. This
company is currently constructing a municipal wastewater
facility for the City of Hercules in Northern Calif orni-a.
I would like to read a short summary of the benefits Solar
Aquacell Wastewater Reclamation process can provide and give
some comparisons to proposed facilities.
First is energy use. Solar Aquacell uses one-half to
one-fourth the operating expense3 with energy costs greatly
reduced through solar energy and possession of bio fuels.
With the anaerobic 3 covered Aquacell pond3 a net energy pro-
duction can be achieved.
Currently 3 the wastewater plant is the largest nonwater
department user of electricity3 consuming 2.4 million kilowatt
hours per year. Both of the alternatives suggested by Brown
and Caldwell3 0D^3 and one we are not supposed to talk about3
0D?3 would use fwe and three times the present rate3 respectively.
How about land use? According to Solar Aquacell3 only
a small land area of one acre per ten thousand people is
needed for secondary treatment.
Gruen Gruen + Associates on JPage 533 of the Draft EIS/EIR
says the total study area in 1999 will have a population
of around 27730003 in conflict with what the person from
Jones & Stokes said. That population would require a land
area for treatment of just under 28 acres.
In the Solar Aquacell System3 toxins3 heavy metals3
pesticides3 herbicides3 pathogens3 and carcinogens are metabolized
by the hardy water hyacinths3 and detoxified and sterilized
by ozone. Total dissolved salts can be reduced by ten to
twenty percent by the biomass uptake3 while the natural pre-
cipitation and evaporation losses are eliminated.
There is a short construction time -- about six months
on the average — and environmental benefits greatly reduce
project delays and costs. Actually, this kind of system
is only one-half to one-quarter the construction cost of
conventional technology.
The reclaimed water from OD/EEsa and B has an average
cost of $745 per acre foot compared to $200 per acre foot
for the San Felipe Project mentioned on Page 417 of the EIS/EIR.
Using the cost from Solar Aquasystems of 25 cents per thousand
gallons of reclaimed water3 one acre-foot would cost only
$81.67.
On the same paget the Draft saysa "The high cost of
these two reclamation alternatives appear extreme when compared
to the nonreclamation options, but the cost of developing
alternative water supply sources in the future should also
be considered".
149
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We must not be satisfied with partial solutions to the
problems we are now faced with. Only a systemic approach
can provide satisfactory solutions to our situation. I do
not consider myself an expert in this field, but I do think
the evidence I have presented deserves more attention than
it has received.
I urge the EPA to recommend coverage of these innovative
systems before reaching a decision.
Responses. The Draft EIS/EIR does not "condone" any
particular treatment method. It is, by law, a full disclosure
document that describes and analyzes the impacts of the various
alternative projects developed in the facilities planning
process. Concern for resources is given in economic terms
in determining the most cost-effective alternative.
This comment is responded to in the "Supplemental Analyses"
section of this chapter (page 186).
The 277,000 population figure presented on page 533
of the Draft EIS/EIR is for the entire project study area.
This includes large land areas that are not and will not
be served by the Santa Cruz wastewater facilities (e.g.,
northern Monterey County, primary and secondary reclamation
areas, Wilder Ranch, County Area B, Watsonville 201 area).
Mr. Rushton's presentation referred to a 1999 service area
population of 221,000. This includes only the area likely
to be served by Santa Cruz wastewater facilities by 1999
(e.g., Santa Cruz, County Area A", East Cliff/Capitola, Aptos,
La Selva).
This comment is responded to in the "Supplemental Analyses"
section of this chapter (page 186).
David Bockman
Comments. First of all 3 it should be pointed out that
the City of Santa Cruz is operating under a cease and desist
order3 No. 7901, adopted by the Regional Water Quality --
the California Regional Water Quality Control Board Central
Coast Region in San Luis Obispo on February 9th of 1979.
This is an order requiring the City of Santa Cruz and Santa
Cruz county to cease and desist from discharging waters contrary
to requirements described by the California Water Quality
Control Board Central Coastal Region. Amongst other things3
it sets out^ under -- on Page 4 of that order a series of
compliance dates.
Basically 3 they have two different categories. One
if the City of Santa Cruz receives a waiver from secondary
treatment3 and if the waiver is denied. It indicates here
that the date the waiver would be granted or denied is April
Istj 1980. Full compliance wi*th requirements is December 1st,
1982. Obviously this cannot be met.
150
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Indications are, I believe, that the EPA has stated,
and also Mr. Jones, the Executive Director of the Regional
Water Quality Control Board, only a few days ago that the
granting of the waiver or denial would probably occur on the
order of two years from now, not -- not on April 1st, 1980.
Perhaps I should clarify.
In any case, the statement was made by the state and
by the EPA on various occasions that the city must go ahead
with what they are proposing because they have to do it or
otherwise somebody's going to throw them in jail or something
like that. I don't think that's the case. And I think what --
what the EPA should be doing here and it should be studying
in this document is what should he -- what's best for this
region in terms of protecting water quality and improving
water quality. And if this takes a little bit longer, so
be it. I think that's what should be done.
First of all, at -- there is -- in the front, there
is a series of locations where this document was sent, and
it was sent to various state agencies. It was sent, for
example, to the State Water Resources Control Board, Division
of Water Quality, Mr. Neil Dunham. Within the State Water
Resources Control Board there is an Office of Water Recycling,
which was established in 1977 by the Governor of this state.
I know that this document was not sent to the Office of Water
Recycling.
On Page 446 of this document, it indicates the various
state agencies to which this document was referred for in
the preparation of the Draft EIS/EIR, and it lists the California
State Water Resources Control Board, various people within
that agency. Not a single person with the Office of Water
Recycling was consulted in the preparation of this document.
Obviously, the State has an interest in reclaiming water.
It '8 pointed out on -- on -- on Page 14 of the document
the one thing that, "In January, 1977, the State Water Resources
Control Board provided a major stimulus to water reclamation
by adopting the 'Policy and Action Plan for Water Reclamation
in' California".
I don't believe this EIS/EIR that's before you tonight
addresses that plan and action -- that Policy and Action
Plan adopted by the State.
In October, 1977, Governor Brown established the Office
of Water Recycling. In creating this office, the Governor
set an initial goal of tripling California's use of reclaimed
water by the end of 1982.
151
-------
I don't believe this document that's being presented
here tonight addresses the concerns of the State of California.
I think the previous speaker probably best indicated
the system that could be utilized in this case. The system
he described has been developed by Solar Aquasy stems, and
other firms have been involved in similar systems. And the
plant is being constructed in Hercules, California, at this
time, and it is expected to go into operation in 19— in
November of this year.
So why -- why is this not being discussed in this Draft
EIS/EIR? The statement is made3 'Well, we never heard of
it until this week'. On the other hand, there was an article
written in the Los Angeles Times on April 21st, 1976, entitled
"Hyacinths Thrive on Sewage, Clean Polluted Water", reporting
on a paper presented by Mr. Bill Wolverton of the National
Aeronautics and Space Administration, a federal agency which
is, I think, probably well known to you, to EPA.
The fact that -- that EPA issued an NPDES for the City
of Hercules for their plant, which I believe is capable of
actually 2,000,000 gallons per day, about one-tenth the size
of this unit that's proposed here, is indication that it,
EPA, is willing to consider innovative proposals.
But these are not being considered in this Draft EIS/EIR.
Where is this information? And it has to be considered here,
and it was never considered by the Board of Control or by
the -- the consultants for the Board of Control or by Jones &
Stokes. There is no evidence that any of this was ever con-
sidered at any point in the discussions.
It's obvious that the City has very great interest in
protection of the -- the -- the park area at Nearys Lagoon
and has no intention as the -- for expanding into that area.
If 1st d%d, we would have to wvpe out the exi*sti*ng park in
that area.
I would like to make one major correction in the --
in the text. On Pages 253 and 254, there is a section entitled
'California Coastal Zone Conservation Commission'. As you
know, or at least you should know, the California' Coastal
Zone Conservation Commission became extinct on January 1st
19J-7i Td ir/Plaoei,bV California Coastal Commission,
which has followed from the passage of the California Coastal
'I'," 1Sl , , \e ^^oussion here in terms of conformance
with Coastal Act policies is at this point archaic, and there
should be substantial discussion m the Draft BIS/EIR about
conformance of the proposed project with Chapter S of the
California Coastal Act of 1976, which establishes certain
policies for protection of the coastal zone in the State
X Silt l"' I t* ie completely deficient in
that respect, and I would ask that document — document
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be substantially amended to -- to reflect the positions taken
by the State of California in passing the California Coastal
Act in 1976.
Responses. It is very likely that the schedule for
action on Santa Cruz's application for secondary treatment
modification, as reported in the City's NPDES permit, is
overly optimistic. It is impossible to estimate when action
will be taken on the application. In the interim, however,
Santa Cruz must show progress in planning and initiating
design work to bring its discharge into compliance with federal
and state water quality requirements. In this regard, the
city plans to request a Step II grant for design of an extended
ocean outfall and treatment plant modifications. The RWQCB
must judge whether Santa Cruz is making timely progress
toward compliance with the requirements of its NPDES permit.
If the city wishes to devote more time to the planning phase
of its facilities planning effort in order to reconsider
wastewater reuse options, the RWQCB must be convinced that
this is appropriate.
Staff of the SWRCB, Office of Water Recycling, were contacted
numerous times by Brown and Caldwell during the facilities
planning process. Direct contact was not made by preparers
of the Draft EIS/EIR.
Several copies of the Draft EIS/EIR were forwarded to
the SWRCB for its review. These documents should have been
circulated internally to the various offices and divisions
within the agency, including the Office of Water Recycling,
Division of Water Rights, etc.
The plans and policies of the SWRCB have been given
serious consideration throughout the facilities planning
process. This includes its policies advocating water reclama-
tion and recycling. SWRCB staff were active participants
in the project's Interagency Advisory Committee, which played
an important role in recommending alternatives to be considered
in detail by the EIS/EIR. Numerous water reclamation schemes
were considered by the facilities planners, including two
which received detailed coverage in the Draft EIS/EIR (OD/RE5
and OD/RE7). The Project Report (Brown and Caldwell, 1978c)
recommends that Scotts Valley effluent be used to supply
a local Santa Cruz market (golf course and greenbelt irriga-
tion) and that Watsonville effluent be considered for use
as a barrier to seawater intrusion. Cost estimates prepared
by Brown and Caldwell suggest that reclamation and reuse
of Santa Cruz's effluent is not cost-effective at this time.
The state is promoting wastewater reclamation only where
it can be proven to be economically and environmentally sound.
This comment is responded to in the "Supplemental Analyses"
section of this chapter (page 186) .
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Communication with the City Department of Parks and
Recreation indicates there is no conflict between Nearys
Lagoon Park Phase II development and potential expansion
of the treatment plant under Alternative 0D^A (Thiltgen,
pers. comm.). Plans for park improvement are focusing on
the meadow area to the north and west of the treatment plant
berm and the open water area to the northwest. Proposed
treatment plant expansion would occur to the northeast and
would not include any of the park area being developed in
Phase II of the park development plan.
The current structure and policies of the California
Coastal Commission, as specified in the California Coastal
Act of 1976, are described in a response to a written comment
made by the Central Coastal Regional Coastal Commission (Page 63).
Wallace M. Dale
No response required
William Doyle
Comments~ The concern with a long ocean outfall, as
for as I'm concerned, is that the recommendation in both
the combined EIR and EIS is for the 1C alignment 3 and I think
the position of the outfall is probably of greater importance
to many people than is the type of treatment because of the
specific location of Santa Cruz and the specific location
of the -- of an ocean outfall.
So3 to summarize, I think my comments -- I would prefer --
I would like to see more attention given to an evaluation
of the 1C outfall versus the ID outfall. And I think the
extra margin of safety when you av& investing this much in
an outfall3 the extra amount of money might be worth being
spent at this time, although it's a very local concerns it's
just research at a marine station.
Now, the other concern is3 then} just the primary versus
secondary treatment} and I have seen no persuasive argument
for the need for secondary treatment where this particular
outfall terminus is to be put. And I say that in spite of
the fact that the person -- the people who are going to get
hit hardest if there is a problem are going to be the people
at the Marine Lab because you are taking it up into our intake
system.
Responses. The Draft EIS/EIR made no recommendation
for a preferred ocean outfall route, it simply identified
the impacts of the various alternatives. The Project Report
the plan engineers (Brown and Caldwell,
1978c) , recommended use of outfall Route lc if the treatment
plant is to remain in Nearys Lagoon.
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Dr. Doyle raised a similar concern in his written comments
on the Draft EIS/EIR. Refer to the "Written Comments" section
(page 103) of this chapter for a response.
Dr. Doyle has expressed a concern that secondary treatment
may not be necessary for a deep water discharge to waters
off the Santa Cruz coast. He suggests that primary treatment
may be more appropriate. EPA has elected not to address
the "primary vs. secondary" treatment issue for Santa Cruz
in the text of the facilities plan EIS. This issue is being
dealt with in great detail through the Clean Water Act 301(h)
process. The acceptability of a primary ocean discharge at
Santa Cruz will be judged in acting on Santa Cruz's request
for modification of the secondary treatment requirement.
A further chance for public input into this decision will
be available when EPA sponsors hearings on the Santa Cruz
application.
Ralph Kenworthy
No response required.
Deena Hurwitz
Comments. What of efficiency? The Nearys Lagoon Plant
is Santa Cruz 's largest individual energy consumer at two
and one-quarter million kilowatt hours per year. Compare
that to the 500 kilowatt hours per month which is a high
PG&E estimate for an average household.
As for ecology, the more water we direct and drain without
adequate replenishment and reclamation, the less water we
will have available3 especially with a propensity for drought.
And we should also look at the chemical nature of waste
outfall off our coast. Even with comprehensive waste treatment,
the question must still he raised as to the harm of the treatment
chemicals as they build up in years of effluent discharge.
Without secondary treatments a greater concentration of chemicals
would be required to meet treatment regulations.
What i8 the savings in cost compared with the added
chemical intensity?
Even with these questions satisfieds we always need
to be looking for better solutions. Cost estimates, population
and energy use are increasing exponentially. Will it still
be efficient, economical and ecological in 20 years to treat
our sewage as we do now and keep looking for new water sources
and areas for landfill? We have to begin now to plan for
the future.
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Although still a pioneering field, aquaculture as wastewater
treatment has inspired prominent research from NASA to Solar
Aquasystems, Incorporated, which we heard some about. This
firm is currently building a system for the City of Hercules,
California.
In fact3 the 1977 Clean Water Act requires that agricultural
and aquacultural alternatives for wastewater reuse be evaluated
and encouraged as treatment mechanisms.
Obviously this is but a simplified evaluation of wastewater
treatment options. An increased emphasis on on-site wastewater
managementa district-oriented decentralized system, should
be considered as well. This option was adopted in 1973 for
Santa Cruz rural districts.
Responses. The "Supplemental Analyses" section of this
chapter contains a general discussion of energy and recycling
issues as they relate to the Santa Cruz facilities planning
effort. Refer to this section for a response to this comment.
A general discussion of aquaculture is presented in
the "Supplemental Analyses" section of this chapter. Refer
to page 186 for this discussion.
The Central Coast Basin Plan, developed in 1975 (California
State Water Resources Control Board, 1975), suggested that
sewer feasibility studies be completed for the rural parts
of Santa Cruz County, especially the upper San Lorenzo River
subbasin. Septic tank management districts were suggested
for those areas where sewers did not appear warranted.
Regionalization of facilities was recommended for the more
densely populated portions of Santa Cruz County, namely
Santa Cruz, Soquel, Capitola, East Cliff, Aptos, La Selva
Beach, and Sand Dollar Beach. The Santa Cruz facilities
plan is following this regionalization recommendation and
will service most of the contiguous, densely-populated areas
between Santa Cruz and La Selva Beach. Rural areas, including
the San Lorenzo Valley, remain free to consider on-site waste-
water management as an alternative. The major concern with
on-site systems currently being used in rural Santa Cruz
is the potential for surface and groundwater quality degradation.
Leon E. Ellis
No response required.
Jack Collier
Comments. In your EIRS it's recommended on Page 290
that sludge be disposed of by landfill. I would like to
point out that our landfill areas are limited. At a recent
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Civil Engineering Environmental - Conference in San Francisco3
it was pointed out the landfills in the Bay Area would last
about approximately another 20 years. I think the City of
San Francisco currently trucks their garbage to the City
of Mountain View, and when that's filled3 there could be
such places as Livevmore or Santa Cruz.
Sludge is an organic material and should be considered
a resource3 not a waste.
Conversion to a nutrient-rich soil3 once composted.
Vermicomposting or composting by use of earthworms is a pro-
mising economic method of composting sludges into an odorless,
usable and marketable fertilizer. Vermicomposting is considered
an innovative appropriate technology by the State Water Resources
Control Board and the EPA. It is a system of composting
that is environmentally sound3 energy efficient and very
economical.
Responses. The subject of vermicomposting is discussed
in the "Supplemental Analyses" section of this chapter (page 180) .
Diane Livingstone
No response required.
Jane Weed
Comments» Santa Cruz government officials3 large engineering
and consulting firms and many local citizens view sewage and
wastewater treatment as something to deal with to inject
with chemicals and pump it away and3 in this case3 dump it
in the ocean. Out of sight3 out of mind3 except for the
ever increasing costs of energy3 chemicals and further sophis-
ticated technologies to isolate us from our secretions. Historically3
sewage and wastewater have been valuable resources for societies.
And especially today3 when the cost of nonrenewable fuels
are rising so tremendously3 we must plan now for the future
and for efficient3 economic utilization of our resources.
Sewage must be seen as a resource to utilize, not a problem
to deal with.
Santa Cruz can ill afford to overlo.ok the cost-effective
potentials of the methane and nutrient recovery system instead
of leaping into a technological fix.
It is our conclusion that the benefit cost analysis
of the Brown and Caldwell study did not thoroughly explore
or compare the various sewage treatment options as they did
not consider the possibility of an economically self-sustaining
treatment operation3 a hybrid of alternatives.
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Historically, water shortages in Santa Cruz County have
posed very serious dilemmas to agriculture3 industry and
homeowners. At the current time3 the overdraft of water
in the Pajaro Valley is so severe that farmers are now experi-
encing dangerous levels of saltwater intrusion into the valuable
fresh water aquifers so needed in that region for irrigation,
and has resulted in the Planning Commission to commit to
spend anywhere from $25-50 million to construct the Zayante
Dam to impound water. Given that the waste treatment facility
in Santa Cruz will expel between ten and 13 million gallons
per day, it seems imprudent to spend such exorbitant sums
on additional water resources, while there is such a vast
possibility for wastewater reclamation. As has been detailed
before, not only is it possible to utilize this otherwise
wasted resource for agricultural and parkland irrigation,
groundwater recharge and industrial processes, we can also
avoid the economic drain and environmental devastation caused
by such proposed dams and reservoir projects such as Zayante
Dam.
Responses. An expanded discussion of energy consumption
and recycling is included in the "Supplemental Analyses"
section of this chapter. The reader is referred to this
section for a response.
Brown and Caldwell developed and analyzed an initial
list of 23 project alternatives, seven of which included
wastewater reclamation (see Table 8-1, page 8-3 of Brown
and Caldwell, 1978c). While there are obviously other com-
binations and permutations of treatment mode and reuse/disposal
mode that could have been investigated, it is felt that the
most viable options available were given consideration. The
economic feasibility of supplying local reclamation markets
was given special attention (see Chapter 7 of Brown and
Caldwell, 1978c).
Wastewater reclamation comments have been addressed
in a general response included in the "Supplemental Analyses"
section of this chapter (page 182).
Jan Karwin
Comments. First, the report does not provide sufficient
information to predict the long-term effects on marine life
in the vicinity of the wastewater discharge. Apparently
it is difficult to assess the cumulative impact of the effluent.
Second* we are concerned that the cost comparisons of
the reclamation alternatives do not take into consideration
the costs of developing a new water resource. The need
for this additional analysis was recognized in the SIR on
Page 417 where it is observed that, although the costs of
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reclamation alternatives appear- high when compared to the
nonreclamation alternatives, the costs of developing alternative
water supply sources in the future should be considereds
since these water supply options will also have considerable
economic and environmental costs.
Taking into consideration the operation and maintenance
costs3 would it be more economical for local residents to
fund two and a half percent of the capital costs of an innovative
reclamation project after receipt of federal and state grants3
or would it be more cost-effective to construct a comparable
new water resource?
Responses. The Draft EIS/EIR does discuss potential
long-term impacts on the marine environment (pages 341 to
344). That discussion indicates it is unlikely there will
be a detectable short-term impact created by the discharge
of wastewater (either primary or secondary). Chronic toxicity
and long-term impacts are much more difficult to evaluate.
There is little information available that can aid in evaluating
the long-term influence of a specific wastewater discharge
in a specific marine environment. The potential impacts
of Santa Cruz's discharge are receiving a more thorough analysis
through the Clean Water Act's 301(h) review process. EPA
will be reviewing all available data on potential impacts
before acting on Santa Cruz's application for modification
of the Clean Water Act's secondary treatment requirement.
An additional discussion of wastewater reclamation is
included in the "Supplemental Analyses" section of this chapter
(page 182).
Neither the facilities plan (Brown and Caldwell, 1978c)
nor the Draft EIS/EIR have developed a detailed cost compari-
son of wastewater reclamation alternatives and alternative
water supply developments. This information would be of
benefit from a local planning standpoint, but the task of
preparing the analysis is beyond the scope of the wastewater
facilities planning efforts being funded by the 201 grant
program. Brown and Caldwell (1978c) does list rough estimates
of water supply projects (page 4-6), with costs per acre-
foot ranging from $83-$296. These numbers can be compared
to the reclamation project water costs estimated to range
from $318-$767 per acre-foot (page 9-16 of Brown and Caldwell,
1978c).
Ronald Pomerantz
Comments. Nothing from the water reclamation or sludge
sales will accrue under this plan. If north coast farmers
pay what they are paying now -- that's roughly ten cents
per thousand gallons -- the City would earn some $1603000
a year by selling the 5,000 aare-feet of the reclaimed water.
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As water use increases and supplies diminish over the
next 20 years, this water's value will understandably go
up proportionately. Suoh water use will detain the need
for the go-ahead with the proposed Zayante Dam.
No mention of aquaaulture or poly culture systems were
mentioned, which are safer, cheaper and provide the jobs
that are absolutely necessary for this town,
No mention of a hybrid-type system was put forth by
Brown and Caldwell. That would be something to the effect
of upgrading Nearys Lagoon and then pumping for advanced
secondary to tertiary treatment up at the West Site, the
far West Site in Santa Cruz. They don't have to reclaim
the entire 21,000,000 gallons of water.
Brown and Caldwell left out any mention of on-site recovery
treatment, which requires pretreatment. Such a requirement
for a system such as a tannery would alleviate vast public
expenditures at the treatment plant end. Such planning would
also save energy costs and in the long run save Salz Tannery 's
supplies and materials as those costs rise.
Inconclusive proof -- the -- the -- Under OD^ and OD,.
or B, using the standards of the EPA, the ammonia discharged
will -- will exceed permissible levels by some three or four
times. Inconclusive proof has been presented that safe levels
of arsenic and chromium will be discharged.
In the Draft EIR supplement, a statement on Page 1 says
that 75 percent federal and 12 and a half percent state
financing can be obtained. No mention was made regarding
implementation of new alternatives or innovative systems
under EPA law which would qualify for 85 percent federal
funding, 12 and a half percent state funding and two and
a half percent local funding.
There is no mention of the environmental, social or
economic impacts of such a plan compared to water reclamation.
This is especially important in light of the Zayante Dam
that is planned. And the cost is uncertain at this point.
Some $25 million to $50 million. That cost factor is really
essential to understand how water reclamation is a feasible
alternative if you take into account that $25 million to
$50 million Zayante Dam project.
Just briefly touching on the energy issue once again,
in the -- from 1982 to 1999, Brown and Caldwell figures,
energy cost will increase some tenfold. The energy issue
at the plant as outlined already, there is the -- theu are
the single largest user of electricity as well as natural
gas. Those figures are two and a quarter million kilowatt
hours of electricity a year and six and i billion BTU's of
naturalgas. It's -- nowhere in the Brown and Caldwell report
or the EIR is this issue addressed of the energy supply.
Page 21of the supplement to the — of the EPA Environ-
mental Impact Report, "there is still a question as to whether
or not passing toxics through a biological process..." this
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is a quote. "may alter the•chemical state and therefore
detoxify some wastewater constituents. This question has
not been thoroughly addressed in the scientific literature
to date. "
That should be pursued much further.
Responses. The reader is referred to Response Number
3 to Mr. Pomerantz's written letter of comment.
The aquaculture alternative is discussed in the "Supple-
mental Analyses" section of this chapter (page 186).
The specific split-plant alternative you refer to was
considered in Brown and Caldwell (1978c, page 8-56). Splitting
of facilities makes operation and maintenance more difficult
and more costly. It is felt that if wastewater facilities
are to be located outside of Nearys Lagoon, it would be best
to remove all treatment processes, as in Alternative OD41J.
Industrial pretreatment is discussed in detail in Santa
Cruz's Application for Modification of Requirements of Secondary
Treatment (Brown and Caldwell, 1979, Part E). The city already
has a pretreatment ordinance, but this will be modified and
strengthened in order to reduce toxic pollutant loads reaching
the treatment plant.
The State Ocean Plan set specific limits on levels of
ammonia, arsenic and chromium in the receiving waters of
ocean discharges. Brown and Caldwell's calculations indicate
initial dilution of the effluent will be sufficient to meet
these receiving water standards. A rigorous water quality
monitoring program will be required as part of Santa Cruz's
NPDES permit, so that unacceptable levels of these constituents
can be detected and treatment corrections be made.
The omission should be corrected. As you have mentioned,
EPA can make a larger contribution to the planning, design
and construction of innovative or new technology alternatives.
However, these alternatives must be shown to be cost-competitive
with other alternatives being considered. The reclamation
alternatives developed in the Project Report are much more
expensive and energy intensive than the alternatives still
being pursued by Santa Cruz. Cost data developed by Brown
and Caldwell for an aquaculture alternative (page 189 of this
report) indicate this innovative treatment would also be
extremely expensive.
This comment is responded to in the "Supplemental Analyses"
section of this chapter (page 191).
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Energy consumption comments have been responded to in
a general discussion included in the "Supplemental Analyses"
section of this chapter (page 180).
The relative merits of primary and secondary wastewater
treatment have not been further analyzed in this EIS/EIR.
Santa Cruz's application for modification of the federal
secondary treatment requirement is being used as the vehicle
for this assessment (Brown and Caldwell, 1979). EPA must
consider the relative benefits of these two treatment modes
as they relate to a discharge off of Santa Cruz before action
on the application can be taken.
Glenn Specht
Comments. I would like to mention in regard to the
report itself that I find some problems with the statistics,
which leads me to believe that there may be other problems
with the statistics and put the entire report in doubt.
For instance, I can tell you that the estimated population
of the Aptos community of 14,000 is absolutely and positively
wrong. For exactly that area recently, I have had reason
to count the registered voters* and I can tell you that there
are more than 9,000 of them within that area, which you say
has a 14,000 population.
If you take a look in the same area of the land usage
in institutional usage, and that's schools and churches,
you have 140 acres.
Well, gentlemen, Cabrillo College is in that planning
area, and it has 120 acres. There are two elementary schools,
about 11 to 20 acres apiece, and a junior high school with
20 plus acres, and there are ten or more churches from one
to seven acres. And if Aptos High School is included in
that planning area -- and I do believe the line goes near,
but perhaps not to it -- there is another 60 acres.
In other words, I have identified rather handily that
you have about a SO percent problem there, and there are
at least probably another ISO acres that you haven't counted.
I also have some problems with the funding figures that
are considered when it comes to reclamation. It's not exactly
clear, and perhaps you are subtracting from the costs of
reclamation first what it would cost to throw that water
away. In other words, since you are going to have to treat
it to a degree before you throw it out into the outfall to
start wtth, that amount of cost of any reclamation program
certavnly should not be lai*d back on the bar of reclamation.
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It's also obvious to anybody that you are nu u
to be able to reclaim the total volume going through the
plant and> therefore 3 do not need to treat to reclamation
standards the total volume going through the plant. And
I would certainly hope that your reolamation figures reflect
not then the cost of total treatment of all waters to reolama-
tion standards3 but only treatment of those waters that will
be used for reclamation to reclamation standards.
I should also hope that those figures reflect costs
recoverable, certainly not any -- at any more than the growing
the going rate for water. I would not ask anybody to pay
me more to use reclaimed water than they might have to pay
to' use Soquel Creek, eta. But those costs are recoverable
and should be figured into the cost of reclamation.
I think if at that point you compare it with what it's
going to cost to generate clean water sources to provide
these same waters, I think that it comes out quite economical,
in fact, to consider resource reclamation, particularly in
the area of water.
There is an industry which does have an impact both
on water usage and water quality which does not seem to have
gotten mentioned, or at least not where I was reading. Com-
mercial laundries and/or water softeners have a couple of
impacts. Not only are they great water users and returners
of waters to the waste stream, but they are responsible for
a great deal of the salts, the nitrates in the waters, and --
and that you will find the president of their association
at almost any Water Quality Control Board meeting making
sure of their interests because they are very much concerned
that they not be refused the freedom of back-washing salt-
activated water softeners into the wastewater stream. And
it seems to me you might eliminate some of the very costly
cleaning up of wastewater by eliminating the dirtying of
it in the first place.
Responses. The comment suggests that the Draft EIS/EIR
erred by underestimating the population of the community
of Aptos. The EIS/EIR shows a population of 14,500 (permanent
and UCSC student related) in the Aptos service area in 1979,
up from about 13,400 in 1976.
It is possible that the 1976 Special Census undercounted
the Aptos population. A background memo for the EIS/EIR
(August 20, 1976) notes that the 1976 census-based estimate
for the Aptos/La Selva Beach area of 14,800 is 600 less than
the 1975 estimate for the same area done by James Montgomery,
Engineers. But this difference would not approach the 27,000
population Ms. Specht infers in 1979 based on a formula she
cites for estimating population from the number of registered
voters (three times registered voters *= total population).
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It is possible that the formula either is inaccurate
in general or that it is inaccurate with respect to Aptos.
It could be inaccurate in general if it was based on 21 as
the voting age (which was the case in 1970); the multiplier
of three would have to be reduced to reflect a voting age
of 18. It could also be too high with respect to Aptos if
(1) Aptos median age is higher than the state's (fewer persons
under 18) or (2) the ratio between registered voters and
other persons 18 or over was higher in Aptos than in the
state as a whole (which Ms. Specht suspects probably is true).
In the state as a whole in 1970, almost 39 percent of the
population was younger than voting age (then 21); 33 percent
was younger than 18 (now the voting age). 3^f every adult
in Aptos is a registered voter, jLf the number of registered
votes is 9,000 and if^ Aptos's age structure resembles the
general population of the state, a nonvoter population of
5,000 is not impossible, as that would be about one-third
of the population. Because Aptos's age structure is older
and its proportion of registered voters higher, a registered
voter population of 9,000 in a total population of 14,500
is plausible.
In summary, indications are that the Aptos population
may have been undercounted in the 1976 Special Census, but
not nearly to the degree Ms. Specht's comment suggests.
The Draft EIS/EIR estimates 160 acres in institutional
land use (Table 3-39, p. 144), while Ms. Specht enumerates
120 in Cabrillo College alone, plus another 160 or so in
other public schools and churches, indicating an undercount
of about 120 acres.
The land use estimates for Aptos covered a total area
of 7,320 acres. Existing land uses were read for traffic
zones using land use maps prepared by Geo-Science, Inc., from
U. S. Army Corps of Engineers infrared aerial photographs.
The land use data were not ground-checked, and without such
a ground-check (which is a costly undertaking) errors are
bound to arise.
However, such errors are generally errors of distribution
rather than of magnitude. The counts probably do not under-
estimate total development, but rather distribute it to the
wrong land use categories. An undercount of institutional
acreage would therefore be likely to be offset by an overcount
in other land use categories. While public service needs
(such as for wastewater capacity) could be affected it is
not clear that they would be underestimated; thev miaht in
fact be overestimated. ' Y mi9nt in
The costs of reclaimed water (shown in Table 9-R nf
Brown and Caldwell 1978c) are based on the cost for the
reclamation facilities only and do not include the costs
for the basic secondary treatment portion of the project.
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The individual components of each reclamation alternative
are shown in Table 9-7 of Brown and, Caldwell, 1978c. There-
fore, the unit cost of reclaimed water (Table 9-8) reflects
only the costs for the reclamation facilities and not the
secondary treatment facilities.
The two reclamation alternatives considered in detail
in the Draft EIS/EIR (OD/RE5 and OD/RE7) would reclaim all
wastewater flowing to either the Santa Cruz or the Watsonville
treatment plant, at least part of the year, and would therefore
have to be sized accordingly. Alternative OD/RE5 would reclaim
all of the Santa Cruz plant effluent during the summer months
in order to supply the maximum amount of water to Pajaro
Valley agriculturalists. Alternative OD/RE7 would reclaim
the entire flow of Watsonville treatment plant year round
in order to provide the maximum protection from seawater
intrusion.
The economic analysis of project alternatives did consider
costs recoverable from sale of reclaimed wastewater. Specific
numbers have not been presented in the Draft EIS/EIR, and
recoverable costs were not subtracted from total reclamation
costs. However, the relative costs of reclaiming the water
were listed in Table 9-8 of the Project Report (Brown and
Caldwell, 1978c, page 9-16). They ranged from $318 per acre-
foot for Alternative OD/RE7 to $767 per acre-foot for Alternative
OD/REsa. This can be compared to the estimated unsubsidized
cost of $200 per acre-foot for the proposed San Felipe project.
In reality, it is unlikely that farmers in the Pajaro Valley
would be willing to pay more than the $20-25 they now pay
for an acre-foot of water pumped from groundwater. If 7,500
acre-feet of water were reclaimed annually this would provide
$187,500 of income at $25 per acre-foot. This can be compared
with the estimated $940,000 of annual operation and maintenance
costs for the reclamation portion of Alternative OD/RE5A.
The implications of generating alternative fresh water
supplies are discussed in the "Supplemental Analyses" section
of this chapter (page 191).
No data have been developed specifically for Santa Cruz
on the effect of water softener flushing on wastewater salinity.
A major contributor to wastewater salinity is Salz Leathers,
Inc. Sampling conducted for the waiver application (Brown
and Caldwell, 1979, Table E-8 of Part E) suggests that other
industries also contribute significant quantities of dissolved
solids. Data in the project report (Brown and Caldwell,
1978c, Table 4-9) indicate the TDS of the Santa Cruz water
supply is in the range 200 to 300 mg/1. Effluent TDS for
the sampled industries (Table E-8 of Brown and Caldwell,
1979) was in the range 1,600 to 6,800 mg/1. Therefore,
industrial use contributed an additional 1,400 to 6,500 mg/1
TDS which could account for the high wastewater TDS. Since
165
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the water supply TDS is reasonably low, it is doubtful that
there is extensive home water softening in Santa Cruz. An
analysis of the impacts of home water softeners on wastewater
TDS was conducted for the City of Watsonville by Montgomery
Engineers. Although strictly a telephone survey, the analysis
indicated that most regeneration of water softeners was done
off-site by commercial water softener companies either in
Santa Cruz or Monterey. Therefore, these commercial establish-
ments may be contributing large quantities of TDS in regenerating
water softeners from areas outside Santa Cruz, but as yet
there are no data to estimate their impact.
Robert Hall
Comments. Alternatives such as wastewater reclamation
and alternatives for water storage have not been given much
consideration by commissions dominated by engineers and specialists
in wastewater disposal. I believe that they have overlooked
many opportunities to look into alternatives.
Little mention was made3 for instance3 by the people
for an advanced primary treatment plant and outfall into
the ocean or the concern of another group represented here
also for a big dam on the Zayante Creek. Likewise3 the high
dam people made little or no reference to methods of conservation
dealing with recycling of wastewater. Conjunctive water
use3 intradistrict ties3 was barely addressed while intra-
district sewage plants were amply justified by the report
before you.
Responses. Wastewater reclamation is given further
consideration in the "Supplemental Analyses" section of this
chapter (page 182).
Bill Quealy
Comments. The EIR states that septic system failures
are primarily due to adverse groundwater conditions3 but
the watershed study plan suggests these failtures are3 aside
from people needing new systems3 the result of leach fields
being too low for the root zones of plants to clean the water.
That's tertiary treatment.
Rather than recommending removal of septic systems in
the valley and hook everybody up to the dam3 it would seem
more appropriate to revegetate the area.
There was a hyacinth proposal for Santa Cruz3 for which
there were no EIRS and at which many questions were left
up in the air.
166
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Responses. A recent draft, report titled San Lorenzo River
Watershed Management Plan (Santa Cruz County, Office of Water-
shed Management, 1979) discussed causes of septic tank failures.
The principal causes of septic tank failures in San Lorenzo
watershed are:
a. Poor location. Many septic tanks are located close
to streams where groundwater table is high, in steep
terrain, or in areas where soil permeability is low.
b. Inadequate design. Tank and/or leach field size is
substandard. In addition, many on-site systems were
originally intended for seasonal use but are now used
year-round.
c. Improper maintenance. Septic tanks are not properly
maintained -and periodically cleaned.
d. High density. The density of septic tanks, especially
around streams, exceeds the capacity of the soil to
treat the waste.
The depth of the leach field appears to have a greater
impact on the effectiveness of treatment provided by the
system rather than the failure rate, but it would compound
the problem in areas with high groundwater table.
Reclamation using water hyacinths is discussed in the
"Supplemental Analyses" section of this chapter (page 186).
Tony Ryals
Comments. I'm speaking for the Nutrient Energy Resources
Committee. We, for one, want you to consider the toxicity
of chlorine and its impact on ocean or land disposal very
seriously. Alternatives such as ozone, pasteurization, ultra-
violet radiation and degradation by beneficial organisms,
that is microbes and plants -- Max Planck did work with that,
you know, different things -- have not been adequately con-
sidered as alternatives to chlorination.
Next, we would like to pay particular attention to the
outfall's environmental and economic impact on water supplies.
We already have serious water supply problems and feeding
a larger outfall will add to the stress on our supplies,
including necessitating of sizeable damming operations.
The costs, both environmental and economic, of the $25-
50 million Zayante Dam must be considered as part of the
outfall'8 impact.
Last, but far from least, we must go on record to insist
that your EIR's, whether for primary or secondary treatment,
or whether here in Santa Cruz or elsewhere in the United
167
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States, begin to consider the environmental impact of ocean
or river dumping of wastewater or nutrient-loaded sludge3
mismanagement 3 with the environmental impact of such fertilizer
mining as the Florida phosphates and the radioactive slag
wastes it produces -- and I'm sure you know about that3 hut
you have got to start adding the twoy the Florida waste3
that the outfall is the phosphate -- no joke -- plus the
energy and environmental problems its continuous transport
into our county means relative to recycling.
Responses. Chlorine was the only disinfection technique
investigated by Brown and Caldwell. Other methods such as
ozone, ultraviolet radiation, and pasteurization are typically
more expensive and much more energy intensive. Since Santa
Cruz already employs chlorination, use of any other technique
would require a significant capital outlay, and maintenance
costs are expected to be higher. To meet a portion of the
chlorine demand, the city utilizes their on-site hypochlorite
generating system, which produces hypochlorite from sea water.
This reduces their purchased chlorine requirements, as
well as the associated hazards.
Discussion of indirect water supply development impacts
are discussed in the "Supplemental Analyses" section of this
chapter (page 191).
Please refer to response Number 1 to Mr. Ryals' written
comments on the Draft EIS/EIR (page 128).
Jerry Busch
Comments. Neither the draft EIS/EIR nor the supplemental
EIS/EIR adequately addresses the impacts on the3 quote3 balance
of' the marine ecosystems into which you are dumping this
effluent. I quote;
Given the present state of knowledge3 it is not possible
to predict in any quantitative sense the overall ecological
impact of wastewater discharged in marine waters.
I quote again:
The environmental effect of the present Santa Cruz outfall
is not known.
I quote again:
Some species may suffer, others may profit from the
toxic constituents present in the wastewater3 not all of
which are even known.
168
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I could go on. You are not proving that you are not
disrupting the balance. You are not proving that you know
this for even secondary treatment. It could well be that
you are not justified in dumping in effluents s any increase
at all over the present dumping. In other words, given your
criteria for maintaining a balance, the burden of proof is
on the lead agencies to prove that you are not disrupting
the balance of these marine ecosystems. And you have not
done that, given the draft EIS/EIR. Clearly you have not
done that.
Responses. As indicated in the quotes you have mentioned,
it is difficult to predict, in a quantitative sense, what
the long-term impact of an extended Santa Cruz outfall might
be on the marine environment. Biologists and oceanographers
have had difficulty in identifying wastewater-related adverse
effects on marine biota in the few instances where detailed
studies have been conducted. Marine discharges of sludge
or waste flows with a heavy industrial waste load are an
exception. However, marine wastewater discharge requirements
developed by the federal and state governments are designed
to limit the discharge of specific wastewater components
that are known to or are suspected of having adverse effects
on marine organisms or human uses of the marine environment.
These discharge requirements (federal secondary treatment
requirement and State Ocean Plan water quality standards)
have been developed after careful consideration of potential
adverse effects on marine ecosystems and are presently con-
sidered adequate to protect the balance inherent in those
ecosystems.
Attempts to better understand the effects of waste discharge
are constantly in progress and the standards regulating discharges
are subject to fluctuation. Clean Water Act amendments pro-
mulgated in 1977 have allowed Santa Cruz to seek a modification
of the federal secondary treatment requirement. The application
for this modification includes a very detailed compilation
of biological, oceanographic and water quality data that
can be used in assessing discharge impacts on the marine
environment (Brown and Caldwell, 1979). Once discharge require-
ments are established for Santa Cruz, a thorough monitoring
program will be required to identify any change in the marine
environment in the vicinity of the outfall.
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Supplemental Analyses Prepared in
Response to General Comments
This section of Chapter 3 deals with questions and comments
that could not be responded to in short, succinct discussions.
In most cases, the subject areas were commented upon by a
number of persons, and further discussion or reconsideration
was requested. Some of the information presented below is
supplemental to the Draft EIS/EIR while other data have been
taken directly from the original text of the Draft EIS/EIR.
Update of Population Discussion
The basic work on the population, economic and land
use forecasts for the Santa Cruz facilities plan EIS/EIR
was conducted in the fall of 1976 and spring of 1977. The
work was largely based on the special census of Santa Cruz
County conducted in 1976. Other important sources of in-
formation relating to population were the University of
California at Santa Cruz, the Monterey County Transportation
Study and the 1970 U. S. Census of Population and Housing.
Comments particularly of Supervisor Patton and of the
California Coastal Commission, Central Coastal Region, point
out that certain changes have taken place since 1976 which
should be noted in the Final EIS. With regard to population,
five general points have been raised (several by more than
one commentor) which are discussed in this section.
City of Santa Cruz Measure O. Measure O (enacted March
1978) requires the City of Santa Cruz to establish a growth
management system and to conform its general plan to the
growth management system by December 1978.
Operation of Growth Management System. The system developed
in response to Measure O will result in an annual limit on
the number of residential building permits issued. The limit
will be set at that number which will result in an overall
population growth rate not exceeding the state's rate of
growth in the preceding year or 1.4 percent, whichever is
higher. Permits will be allocated three times a year by
the Santa Cruz City Council using an allocation system based
on residential review criteria established in the general
plan.
Effects of Measure 0 on Local Growth as Discussed in
Draft EIS/EIR. Between the July 1976 Special census and
the January 1979 population estimate of the California
170
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Department of Finance the population of the City of Santa
Cruz rose at an annual rate of 2.5 percent, from 37,488 to
39,950. The 1979 estimate of 39,950 exceeds the Gruen Gruen +
Associates 1979 forecast of 39,310 (which includes permanent
and U. C. Santa Cruz populations).
It is not possible to make a definitive statement about
Measure O's effect on future population growth because the
permitted growth rate will vary with that of California as
a whole. The state's rate has been about 1.7 percent per
year since January 1977. The overall 20-year rate implied
in the EIS/EIR is 1.6 percent. In the event the state's growth
rate is lower than 1.6 percent over the planning period,
and if Santa Cruz consistently manages growth so as not to
exceed the state rate or 1.4 percent, then the EIS/EIR forecasts
will be slightly too high. Assuming the actual rate over
time works out to 1.4 percent, then the EIS/EIR overstates
city population by just under 2,000 persons in 1999.
County of Santa Cruz Measure J. Measure J (enacted
June 1978) establishes growth management policies for Santa
Cruz County and provides for the enactment of a growth manage-
ment system "to regulate the character, location and timing
of future residential and other development in Santa Cruz
County". The measure applies to the county unincorporated
areas.
Operation of Growth Management System. In implementing
Measure J the Board of Supervisors passed a Minute Order
November 28, 1978 establishing a 1979 growth limit of 2.2
percent in the unincorporated portion of the county (1.9
percent in the rural unincorporated area and 2.5 percent
in the urban unincorporated area). The system operates by
means of permit allocation. Within the established categories,
total permits are allocated on a first-come first-served
basis. There is no prescribed geographic distribution other
than the urban and rural distinction. That distinction is
established by means of the Urban Services Line.
Effects of Measure J on Loaal Growth As discussed in
Draft EIS/EIR. The composite growth rate for Santa Cruz
County portions of the EIS/EIR study area projected by Gruen
Gruen + Associates in the EIS/EIR is 2.3 percent. Table 5
presents a breakdown of the population forecasts by service
area and Table 6 shows the growth rates. Table 6 also presents
the growth rates established by the city and county growth
management plans (column 2) and potential low-end growth
rates (column 3) which might result from the consistent imple-
mentation of growth management. Column 4 shows the resulting
1999 population.
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Table 5
SERVICE AREA POPULATIONS IN EIS/EIR
1976
1979
1989
1999
Santa Cruz
37 ,649
39,310
43,610
53,800
East Cliff/Capitola
34 , 302
37,370
49,280
62,960
Scotts Valley
6,063
6,760
9,640
14,250
Aptos
13,388
14,500
18,780
25,710
La Selva
1,421
1,590
2,270
3,530
County Area A
3,431
3,580
4,100
5,130
County Area B
-
-
-
-
Wilder Ranch
210
-
-
-
Primary Reclamation SC
7,808
8,100
8,980
11,150
Area Mont
8,375
9,320
13,310
18,990
Secondary Reclamation
343
340
340
340
Area
Service Area Totals
112,990
120,870
150,310
195, 860
In Santa Cruz County
104,615
111,550
137,000
176,870
In Monterey County
8,375
9, 320
13,310
18,990
Santa Cruz County
Tnta 1 c;
159,800
175,500
N.A.
N.A.
N.A. = not applicable.
Source: Service areas, for 1976, EIS/EIR Tables 3-24 and 3-26;
for 1979, 1989 and 1999, EIS/EIR Tables 3-36 and 3-37;
Santa Cruz County totals, for 1976 California Department
of Finance Report 1978 E-4; for 1979, DOF Report 1979 E-l.
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Table 6
PROJECTED EFFECTS OF GROWTH MANAGEMENT SYSTEMS ON
POPULATION GROWTH IN SANTA CRUZ COUNTY
Santa Cruz, City
East Cliff/
Capitola
Scotts Valley
Aptos
La Selva
County Area A
Primary Reclama-
tion Area, Santa
Cruz County Por-
tion
Secondary Reclama-
tion Area
Service Areas in
Santa Cruz County
EIS/EIR
Projected
Growth Rate
1979 to 1999
1.6
2.6
3.8
2.9
4.1
1.8
1.6
Maximum Permitted
Rate under Growth
Management Policy
state rate
2.5 in East Cliff
not applicable in
Capitola
not applicable
2.5
2.5
1. 9
1. 9
1. 9
Potential
Growth
Management
Rate
1
2.3
1.4
2.5 2
2. 5 2
2.5
2.5
1.9
1.9
1.9
2.13
Resulting
1999-
Population
51,900
61,200
11,100
23,800
2,600
5,200
11,800
500
168,100
Notes
1.
2.
3.
A conservative estimate for Santa Cruz assumes the state's growth rate
will average 1.4 percent or less over the twenty-year period.
Conservative estimates for Capitola and Scotts Valley assume they will
limit growth to the 2.5 percent established by the county for urban un-
incorporated areas.
This is the composite rate based on the preceding rates in this column.
173
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The difference between the total population in Santa
Cruz County under the growth management systems as compared
to the EIS/EIR forecast amounts to about 9,000 (176,900 minus
168,100).
However, the actual difference is unlikely to be that
great. For one thing, Santa Cruz city population growth
rates will probably be higher than 1.4 percent consistent
with overall state rates. For another, Scotts Valley and
Capitola, as incorporated cities, are not bound by the 2.5
percent limit established for urban areas by the Measure J
Minute Order. Finally, the Santa Cruz city growth management
system has been established for the period through 1990 and
it is not possible to determine what will happen after that
time.
University of California, Santa Cruz Enrollments. En-
rol lments-at-U*. C~. Santa Cruz now appear unlikely to increase
at the rate indicated in the EIS. Recent and current en-
rollments, together with short-term projections, suggest
stabilization. U. C. Santa Cruz's Office of Planning and
Analysis indicates that long-term projections are no longer
done since the large number of variables would make the accuracy
of such projections questionable. (The 1999 estimate cited
by Supervisor Patton appears in the 1979 Recht Hausrath &
Associates report to AMBAG, but was not confirmed by U. C.
Santa Cruz staff.)
In the EIS/EIR, one component of the population forecast
separately was U. C. Santa Cruz students residing in the
wastewater planning area and their dependents. There are
no recent data on dependents. At the time the EIS was done,
U. C. Santa Cruz staff indicated as appropriate statistics
a marriage rate of 9.5 percent and an average number of de-
pendents of 1.5. About 80 percent of the enrolled students
lived within the wastewater planning area.
At present, a rough estimate of a stabilized U. C. Santa
Cruz enrollment (0.75 average) would be 6,000. Assuming the
residential location and family statistics just cited continue
to apply, that would mean 4,800 students in the service area
plus about 700 dependents for a total of 5,500. This figure
compares to EIS/EIR estimates of 7,390 in 1989 and 8,780
in 1999. Thus, a stabilized U. C. Santa Cruz enrollment
would account for a large part of the difference between
the EIS/EIR forecast and projections based on the growth
rates of the local growth management programs.
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Study Area Population Forecasts for Monterey County.
The Draft EIS/EIR shows (Table 3-36, page 137) a 1999 popu-
lation of about 19,000 in the Monterey County portion of
the primary reclamation area. These estimates were drawn
from 1973 Monterey County Transportation Study (MCT) projections.
More recent data (based on Monterey County's 1976 Special
Census) were considered in the April 1979 report Population
and Employment prepared by Recht Hausrath & Associates for
AMBAG.
The Recht Hausrath & Associates report indicates that,
for Monterey County as a whole, MCTS projected growth appears
to err on the high side. The annual growth rate implied
by MCTS projections is 2.2 percent while the county's actual
197 0-1976 growth rate was 1.6 percent. Recht Hausrath &
Associates recommend a 1976-1995 rate of 1.9 percent.
It is not yet possible to adjust the Draft EIS/EIR rate
(1.8 percent from 1979 to 1999) in light of Recht Hausrath &
Associates work because that work has not been made specific
to local areas (such as the portion of Monterey County in
the study area for this project). At present, it is not
even clear whether an adjustment would be in an upward or
downward direction: downward would be indicated if the MCTS
rate is now judged too high; but upward would be indicated
because the actual rate used by Gruen Gruen + Associates
for this subarea is lower than RHA's recommended rate for
the county. In summary, an adjustment now would be premature.
SWRCB Population Projections and Projection Guidelines.
The SWRCB has established a methodology for translating
California Department of finance population projections
for counties to county subareas such as census tracts or
traffic zones in order to arrive at population projections
for wastewater funding areas. In this particular case,
Gruen Gruen + Associates translated 1970 and 1976 census
data to subareas as a task preliminary to preparing a popu-
lation forecast for the whole wastewater service area. SWRCB
staff reviewed Gruen Gruen + Associates subarea allocations
and accepted them as the basis for its own projections of
the grant-fundable population.
The Department of Finance-based grant-fundable projection
by SWRCB (lower part of Table 8-2, page 377 of Draft EIS/EIR)
is premised on county growth at the rate, specified in the
Department of Finance D-100 population projection series.
This works out to about 2.6 percent per year as compared
to about 2.3 percent in the wastewater service areas (Santa
Cruz, East Cliff/Capitola, Aptos, La Selva and County Area A)
listed in Table 5. The fundable population thus slightly
exceeds the Gruen Gruen + Associates population forecast.
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Mitigation of Wetland Loss
Several individuals commenting on the Draft EIS/EIR
stressed the need for developing a detailed mitigation plan
for any loss of coastal wetland before final wastewater
facilities plans are approved. A detailed plan has not been
prepared to date because the city is seeking to implement
an alternative (OD^) that would not affect wetlands. However,
should the city's application for a modification of the federal
secondary treatment requirement be denied, subsequent imple-
mentation of the city's preferred secondary treatment alter-
native (0D..a) would destroy approximately 2-3 acres of Nearys
Lagoon wetland. This would require some positive mitigation
action by the City of Santa Cruz. The following discussion
provides as much information as has been developed to date
on the likely mitigation scheme.
Strict wetland preservation policies by the California
Coastal Commission (Sections 30233 and 30607.1 of the California
Coastal Act) and the California Resources Agency (Executive
Order 11990) are the major reasons that the city must develop
a mitigation plan if it wishes to expand wastewater treatment
facilities into Nearys Lagoon wetland. The emphasis in these
state policies is that mitigation must replace all losses
"in kind". In other words, for each piece of wetland lost
to development, a new piece of wetland, similar or superior
in habitat value, must be developed as replacement. With
this requirement in mind, several mitigation schemes were
considered for encroachment into Nearys Lagoon. The available
options included 1) selection of an alternative that requires
no major facilities expansion (Alternatives OD_, NP- or NP~) ,
2)' selection of a split-plant option that would locate new
facilities outside of the wetland (Alternative OD. ), 3)
or creation of new wetland on vacant property adjacent to
the Nearys Lagoon wetland. To date, the city has favored
the latter mitigation option if mitigation is indeed necessary.
As mentioned in Chapter 2 (page 10) discussions between
the U. S. Fish and Wildlife Service, the City of Santa Cruz,
EPA and the SWRCB have occurred since issuance of the Draft
EIS/EIR in order to further develop wetland mitigation strategies.
The city has recently purchased additional undeveloped open
space northeast of Nearys Lagoon and could convert part of
this property to wetland as mitigation for Nearys Lagoon
encroachment should Alternative OD^A be. implemented. However,
the U. S. Fish and Wildlife Service has voiced a preference
for the split-plant option as a more appropriate mitigation.
This would avoid filling part of the existing wetland. A
final decision on which mitigation measure will be implemented
(should secondary treatment be necessary) will be made after
preliminary design work better defines the amount of wetland
encroachment necessary and provides costs for the split-
plant option, and the U. S. Fish and Wildlife Service completes
a wetland evaluation of Nearys Lagoon.
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Sludge Disposal Alternatives
Processes Considered During Facilities Planning. Several
persons commenting on the Draft EIS/EIR suggested that sludge
reuse deserved closer consideration by the facilities planners.
Alternative technologies, including composting and use of
earthworms, were suggested as possibly more advantageous
than processing and disposal in the Santa Cruz landfill.
As part of the facilities planning effort, Brown and
Caldwell conducted a detailed analysis of solid waste disposal
and resource recovery options for the entire county. Sludge
was just one of the items being analyzed. All solid waste
generated in the county was considered. A review of current
technology identified 13 solid waste resource recovery processes
that had been or were being tested at various places in the
United States. These processes are identified in Table 7. .
They range from simple methane and carbon dioxide recovery
through anaerobic digestion to extremely complex pyrolysis
and incineration processes aimed at producing fuel gases.
These 13 options were subjected to 2 screening episodes,
including presentations to the facilities plan BOC and IAC.
Three processes were selected as the most appropriate for
detailed consideration: 1) pyrolysis in a multiple hearth
furnace, 2) waterwall incineration, and 3) the Andco-Torrax
process (combined pyrolysis and incineration). A description
of the screening assumptions and reasons for dropping processes
from consideration is contained in Brown and Caldwell, 1978
(pages 5-12 to 5-31).
Selected Solid Waste Alternative. A final screening
of solid waste resources recovery processes resulted in Brown
and Caldwell's recommendation of pyrolysis in a multiple
hearth furnace as the most appropriate technology for use
in Santa Cruz. This process would utilize both sewage sludge
and mixed municipal refuse to produce a fuel gas capable
of running a steam-electric generator. The generated power
would be used to operate wastewater facilities. This particular
process was selected after a cost analysis identified it
as having the lowest present worth (pages 6-3, Brown and
Caldwell, 1978).
As a final step in Brown and Caldwell's analysis, the
selected resource recovery process was compared to the current
method of sludge and solid waste disposal by landfilling.
(Centrifuged sludge is currently hauled to the landfill and
used to cover solid waste, as there is a shortage of cover
material at the site.) The current sludge processing system
was also compared to an alternative process of lime stabili-
zation, dewatering, and landfill disposal. The comparison
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Table 7* . Solid Waste Resource Recovery Processes Selected for
First-Stage Screening3,13
Process
Manufacturer or
con sulta nt
Process description
c
Process status
Remarks
Production of
RDF for boiler
fuel
Union Colliery
Company, St. Louis,
MO
RDF used as a supplement
to coal in a suspension
fired boiler.
30 TPH test facility
operated in St. Iouis,
MO, 1972 until early
1977.
Mechanical system development and boiler firing of RDF and coal
vere successful with RDF providing up to 18 percent of the input
heat value to a suspcnsion-flred boiler. Political constraints have
forced the project into temporary suspension. RDF has also been
used successfully on stoker-fed boilers in Ames, IA.
Flash pyrolysls
Occidental Research
Corporation, La Verne,
CA
Flash pyrolysis of fine, dried
RDF for the production of
heavy oil.
200 TPD plant in start-up
testing at El Cajon, CA;
2000 TPD plant under
construction at Bridgeport,
CT .
Aluminum, ferrous metal, and glass are recovered In a front-end
plant. The manufacturer's projected output of one barTel of oil/ton
refuse Is destined for oil fired boilers after blending with No, 6 fuel
oil. Occidental Research projects a 1000 TPD plant, which requires
10 to 12 acres of land, as the minimum recommended plant size.
Purox
Union Carbide
Corporation, New
York, NY
Pyrolysis and incineration of
shredded refuse in a vertical
shaft furnace using pure
oxygen. A fuel gas is
produced.
200 TPD test facility on
line since 1974 in South
Charleston, WV.
Ferrous metal is recovered in a front end plant. Output gas has 300
to 400 Btu/SDCF. Projected output is 25,000 SDCF/ton input refuse.
Union Carbide estimates that a 1000 TPD plant, which requires 10
to 12 acres of land, is the minimum recommended plant size.
Landgard
Monsanto Enviro-Chem
Systems, Inc.,
St. Louis, MO
Combined pyrolysis and
incineration in a two-stage
process using a rotating
kiln followed by an after-
burner. Resulting heat is
used for steam production.
1000 TPD plant in
Baltimore, MD, suffering
start-up difficulties.
Ferrous metal, a glassy aggregate, and steam are to be recovered
from the combusted refuse. Reported mechanical problems and
failure to meet air pollution emission standards recently caused
Monsanto to abandon the project. The City of Baltimore has not
made a final decision about the future of the project.
Pyrolysis in a
multiple hearth
furnace
Brown and Caldwell,
Walnut Creek, CA
Combustion and pyrolysis of
RDF and sludge in a multi-
hearth furnace to produce
fuel gas.
5 TPH full-scale test
completed. A facility
producing 10 m\v of
electricity and 50,000 lb/
hr of process steam is
planned for design.
Ferrous metal, aluminum, and RDF are recovered in a front-end plant.
In the planned facility, fuel gas is combusted and steam produced
for electrical power generation.
Pyrolysis
Enterpri se /DECO,
Santa Ana, CA
Pyrolysis of RDF and rubber
scrap to produce fuel gas
and oil.
50 TPD facility due for
testing in June, 1977.
Ferrous metal, aluminum, glass, and RDF are recovered in a front-
end plant. RDF, enriched with rubber and plastic scrap, is pyrolyzed
to produce high Btu fuel gas and medium weight fuel oil.
Waterwall
incineration
Various manufac-
turers In Europe and
North America
Typically involves direct
incineration of MMR in a
waterwalled unit, with
minimal preprocessing.
Steam produced is used for
power generation or heating
and cooling.
720 TPD plant in Nashville,
TN, running on auxiliary
fossil fuel.
1200 TPD plant in Saugus,
MA, on line in 1976.
720 TPD plant in Harris-
burg, PA, since 1972.
Nashville plant provides heating and cooling. There have been
recurring problems with air pollution control equipment and boiler
components.
Saugus plant provides steam to a local power plant. Air pollution
standards are being met.
Steam at Harrisburg is used for in-house power generation and
sludge drying. No other markets are available.
Modular
incineration
Consumat Systems,
Inc., Richmond, VA
MMR incineration in batch-
fed, modular units, with
or without steam recovery.
Municipal facilities up to
250 TPD on line since
1971.
These small modular units are designed for waste volume reduction
without materials recycle. Auxiliary fuel Is required to meet air
pollution standards. Recovered steam is sold for industrial use.
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Table 7 * . Solid Waste Resource Recovery Processes Selected for
First-Stage Screening3(continued)
Process
Manufacturer or
consultant
Process description
c
process status
Remarks
CPU" 400
Combustion Power
Company, Inc.,
Menlo Park, CA
Application of shredded,
classified MMR to a
fluidized bed combustor.
Off-gas is led to a gas
turbine generator.
100 TPD test facility
operated in Menlo Park,
CA, from 1373 until
1976.
Ferrous metal and aluminum are recovered in a front-end plant. The
CPU-400 has suffered problems with materials handling and turbine
blade fouling. The facility was most recently used by ERDA for
combusting high sulfur coal. No additional solid waste testing is
planned.
Hydrasposal
Black Claw son.
Franklin, OH
Wet pulping of MMR for
pulp production and
materials recovery.
ISO TPD plant on line
since 1971 in Franklin,
OH. targe plants
planned in New York
(2000 TPD) and Florida
(3000 TPD).
Ferrous metals, aluminum, and color-sorted glass are recovered
and processed after wet pulping. Fiber has been used In roofing
paper or can be burned as a fuel. Local economics will govern
minimum plant size.
RefCOM
Waste Management,
Inc., Oakbrook, IL
Anaerobic digestion of RDF
and sewage sludge to pro-
duce methane and carbon
dioxide.
100 TPD plant under
construction in Pompano
Beach, FL.
Materials recovery In a front-end plant, followed by anaerobic
digestion of RDF and raw sludge. Codigestion has only been run
on bench-scale systems. A 1000 TPD plant would require 10 to
20 acres.
Landfill with
methane
recovery
Reserve synthetic
fuels, Newport Beach,
CA, and NRG, Inc.,
Phoenix, AZ
Gas from refuse decompo-
sition drawn from landfill
and upgraded to pipeline
quality.
System operational In
Los Angeles, CA at
Palos Verdes landfill.
A proprietary system is used to adsorb carbon dioxide and other
contaminants from the salvaged gas. The purified product is fed
into the local gas distribution system. Uncleaned landfill gas is
also used to fire an engine generator in the City of Los Angeles.
Andco-Torrax
Andco, Incorporated,
Buffalo, NY
Combined pyrolysis and
incineration of as-received
MMR in a vertical shaft
furnace to produce fuel gas
75 TPD test facility
operated in Erie County,
NY. from 1971 to 1973.
System development is
continuing in Europe.
An aggregate-like frit and low Btu fuel gas (100 to 130 Btu/SDCF;
45,000 SDCF/ton input MMR) are recovered from the furnace. Gas
was used for steam production at the test facility. Minimum
recommended plant size is 150 TPD. Air and wastewater emissions
are minimal.
8 Abbreviations
SDCF - Standard dry cubic feet
TPH - Tons per hour
^All quantities refer to Incoming MMR tonnages.
CAs of April 1977.
~SOURCE; Brown and Caldwell, 1978.
-------
of the existing system and resource recovery option included
an environmental impact assessment prepared by Jones & Stokes
Associates (Table 7-1, Brown and Caldwell, 1978). The impact
assessment clearly favored the resource recovery option in
all categories except cost. Because the resource recovery
option was estimated to cost about three times more than
landfilling, Brown and Caldwell recommended continued land-
filling. Brown and Caldwell's final recommendation stated
"if economic factors should change drastically or be out-
weighed by environmental considerations, then a reanalysis
of resource recovery should be undertaken emphasizing a bicounty
facility since this appears the most cost-effective alternative
at this time" (Brown and Caldwell, 1978). It is therefore
up to the City and County of Santa Cruz to decide whether
environmental benefits outweigh costs in selecting an appro-
priate solid waste and sludge disposal scheme for the Santa
Cruz area.
Vermicomposting. Use of earthworms for processing sewage
sludge was not evaluated for Santa Cruz in the facilities
plan. This process is currently in the experimental stage,
and as yet there are no full-scale installations (EPA, 1979).
At the San Jose/Santa Clara wastewater treatment plant, raw
sludge is first thickened, anaerobically digested, and dried
in sludge lagoons before undergoing vermicomposting (Carmody
and Collier, 197 9). This treatment scheme is similar to
that currently used at Santa Cruz, with the exception that
at Santa Cruz the digested sludge is centrifuged before trans-
porting to the landfill and following drying is buried in
the landfill. Centrifugation reduces the sludge volume by
decreasing the moisture content, therefore reducing trans-
portation costs, drying time, and lagoon requirements. The
project report (Brown and Caldwell, 1978c) recommends a con-
tinuation of the current practice of sludge disposal since
it is the least-cost alternative and there is adequate disposal
capacity at the landfill. This method of sludge disposal
does not preclude vermicomposting for Santa Cruz since, as
in the case of San Jose, the basic treatment processes would
still be required prior to vermicomposting. Therefore,
vermicomposting could be implemented on an experimental
basis now or the city could wait until reliable design
criteria are established to develop a full-scale operation.
At this time, the only advantage for vermicomposting would
be the production of a byproduct which, if marketable in
the area, might defray some of the sludge processing costs
(Brown and Caldwell, pers. comm.).
Energy Consumption
Energy has become a major issue in all planning efforts
in the United States. Increasing costs and decreasing
availability of conventional energy sources have spawned
a wave of alternative energy-producing technologies and emphasis
180
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on the energy aspects of new development. Several commentors
on the Draft EIS/EIR suggested that present and proposed
wastewater treatment and disposal techniques were energy-
and chemical-intensive and did not take advantage of energy
recovery potentials. A brief review of the energy aspects
of the project alternatives therefore seems appropriate.
The Draft EIS/EIR includes an analysis of the energy
requirements of the proposed wastewater alternatives. Table 6-6
(page 287) of the draft lists annual energy use for each
alternative and a narrative discussion of energy use is pre-
sented on pages 348 and 349. The existing treatment plant
consumes about 1.8 million kilowatt hours (Kwh) of electricity
annually. The proposed secondary treatment option (0D-.)
would consume 6.8 Kwh (in 1979) while an advanced primary
treatment option would utilize about 2 million Kwh (in 1979).
Transporting wastewater to the West site for secondary treat-
ment would increase annual consumption to 9.1 million Kwh.
It is obvious that secondary treatment adds considerably
to energy use in wastewater treatment.
The City of Santa Cruz appointed an Energy Management
Committee to study energy consumption patterns in city agencies
and to develop means of reducing energy dependence. This
committee published a Draft-Energy Consumption and Conservation
Survey - Executive Summary in August 1979 (City of Santa
Cruz, Energy Management Committee, 1979). The report identified
the wastewater treatment system as the city's largest energy
consumer, but made a number of positive recommendations on
how this consumption could be lowered. The three largest
energy-consuming processes in the plant are influent pumping,
sludge dewatering and hypochloride generation. Reductions
in influent pumping could best be realized by promoting water
conservation measures similar to those invoked during the
1975-1977 drought. Water conservation results in reduced
wastewater inflows to the plant. The present method of sludge
dewatering (centrifugation) is extremely energy intensive.
The committee suggested investigating combined sludge gas/solar
powered drying beds, land application or sale of sludge as
a soil conditioner. Each of these alternatives would have
its own potential environmental impact, but each is worthy
of further consideration by the city. Hypochlorite generation
energy costs have already been significantly reduced at the
plant. All of the approximately 98,000 cubic feet of digester
gas generated each day is being used to power the plant's
hypochlorite generation facility. In addition, waste heat
from this generation process is being used to heat digester
sludge. Every effort is being made to utilize generated
methane to its maximum potential. It appears that there
are some very positive energy saving features that can still
be built-in to the wastewater treatment and disposal options
being considered by Santa Cruz.
181
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Draft EIS/EIR commentors made several other suggestions
related to energy and resource consumption. Reuse of waste-
water, sludge gas and sludge were all mentioned as means
of reducing dependence on outside energy sources and manu-
factured materials. The nutrient content of wastewater and
sludge could be utilized locally to reduce dependence on
imported fertilizers. Phosphate fertilizers imported from
Florida were mentioned specifically. Reuse of wastewater
treatment by-products has a number of very positive environ-
mental implications, including energy savings, scarce resource
savings and increased self-dependence. There are also a
number of potential problems associated with each. First,
a market must be found for the by-products. Second, the
reuse schemes must be capable of operating within rather
strict public health guidelines that have been placed on
waste treatment and disposal/reuse schemes. Finally, the
reuse schemes must be competitive financially with other
means of handling wastewater treatment by-products.
Wastewater Reclamation
Public Concerns. Wastewater reclamation was the most
pervasive subject of comments received on the Draft EIS/EIR.
Public testimony at the hearing on the Draft was especially
focused on the pros and cons of reclamation. Strong support
for reclamation was voiced by a number of individuals and
agencies, while concern was expressed by industry and union
representatives that the high cost of reclamation would create
a severe economic hardship to the community. Several persons
identified state and local plans and policies that give strong
support to wastewater reuse schemes. This expression of
concern has been stimulated mainly by the engineer's selection
of nonreclamation, ocean disposal alternatives as the most
viable for city implementation. Several persons have suggested
that reclamation was not given full consideration in the
facilities planning process. In order to clarify the situation,
a brief summary of the facilities plan reclamation analysis
and EIS/EIR review is presented in the following paragraphs.
A discussion of the solar aquacell reclamation system is
also included.
Facilities Plan Reclamation Coverage. The wastewater
facilities plan developed an initial array of 23 project
alternatives for Santa Cruz to consider. Of these 23, 10
included some form of wastewater reuse. The reuse ranged
from groundwater injection to food crop irrigation. During
the initial screening of these alternatives, 8 of the reuse
schemes were dropped from consideration. The reasons for
their rejection were listed in the Draft EIS/EIR (pages 596-
604). A brief description of each of the reuse schemes and
the reasons for accepting or rejecting them are included
below:
182
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Repeated. Alternatives.
o RE„ (Advanced Waste Treatment and Total Reclamation)
1 "
1. It was the second most expensive alternative
($124 million in present worth costs). Much
of the cost is for operations and maintenance
and must be paid by local agencies.
2. It has no outfall and therefore lacks flexibility.
If something goes wrong with industrial source
control, there is no place to put the effluent
without contaminating the reclaimed water re-
servoir.
3. It reclaims 18,000 acre-feet of water per year.
The Task C6 draft report states that demand
exceeds the existing supply in the Pajaro Valley
by 16,000 acre-feet per year in 1999. Relative
to other alternatives, this one would produce
more water than is required to satisfy the over-
draft.
4. Harkins Slough is the only apparent possible
site for the 13,000 acre-feet treated water
storage reservoir, but the fluctuating water
level would impact a valuable fish, wildlife
and riparian resource, and there are Indian mounds
in the area which might be inundated.
° OD/REqa and (Seasonal Reclamation of East
Cliff%Capitola ana Aptos Effluent in the Pajaro
Valley)
1. It is not as attractive as 0D/RE5 because only
5,000 acre-feet per year is reclaimed (as opposed
to 10,000 acre-feet per year for OD/RE5) and
the unit cost of reclaimed water is therefore
higher.
2. Since it requires two separate secondary treatment
plants side by side, it requires more land at
Nearys Lagoon.
3. Parallel treatment plants imposes more operational
complexity.
° a.n^ OD/RE(Separation of Tannery and Seasonal
Reclamation of Remaining Effluent in Pajaro Valley)
1. Ocean disposal of tannery wastewater alone may
result in noncompliance with ocean plan require-
ments due to the absence of dilution with muni-
cipal effluent and lack of good initial dilution
in the outfall.
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The New or Innovative Alternatives
o OD/RE^^ (Treatment Plant Relocation and Seasonal
Reclamat%on on North Coast)
1. Agricultural irrigation is only 5,000 acre-feet
per year in this area.
2. This alternative is dependent on relocating
the plant to the West site.
3. There apparently is no extreme water shortage
in this area. Thus, the unit cost for reclaimed
water is much higher than alternative sources,
such as wells.
4. Most of the other alternatives could be flexibly
designed to permit future use of reclaimed water
in the area. The U. S. Geological Survey is
planning a groundwater study of the area which
should aid in defining any groundwater or surface
water shortages and permit reconsideration of
this alternative in the future.
o OD/RE^g (Local Landscape and Golf Course Irrigation
From Nearys Lagoon)
1. The demand is only 150 acre-feet per year, thus
the unit cost of reclaimed water is very high.
2. These markets might be better served by an
extension of the Scotts Valley wastewater re-
clamation system to make use of the available
hydraulic head rather than pumping water from
Nearys Lagoon. The mineral quality of the
Scotts Valley effluent is also superior to that
of Santa Cruz, making it a more attractive supply.
o OD/REq (Seasonal Reclamation of Watsonville Effluent
for Irrigation of Orchards)
1. If fruit continues to be harvested from the
ground, there would be potential health concerns.
Treatment at the tertiary level would be required
to overcome these concerns, making this alter-
native less competitive economically.
2. There is no existing institution set up to
sell the effluent to farmers. This is also a
drawback to OD/RE^ but not OD/RE^.
3. Salt content of Watsonville effluent is high
and may be unacceptable to farmers.
184
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4. Since the orchards are not in the area of de-
pressed groundwater levels of salt water intrusion,
there is less expensive irrigation water available.
5. A more direct and effective way to satisfy the
overdraft situation would be to provide effluent
to the drawdown area either through irrigation
(OD/RE5) and by a "barrier" (OD/RE7).
Accepted Alternatives.
o OD/RE, (Activated Sludge Treatment at Nearys Lagoon,
Ocean Disposal With Seasonal Tertiary Treatment and
Irrigation Reuse in the Pajaro Valley)
1. It is representative of a series of reclamation
alternatives that involve intracounty transfers
of water (OD/RE2A, OD/RE2b, OD/RE OD/RE- ,
and OD/RE,-) . '
2. It will produce 13,400 acre-feet of water per
year in 1999, which is commensurate with the
16,000 acre-feet of overdraft in 1999 as deter-
mined in Task C6. (The incorporation of
Watsonville effluent on" the project could be
used to balance the demand.)
3. It has no significant impacts on Harkins Slough
as does RE^.
4. It is more flexible than RE^ in that it incor-
porates an outfall for Santa Cruz for blowdown
of "off spec" water.
o OD/REr, (Advanced Treatment for Watsonville for Salt
Water Intrusion Barrier1
1. High potential for positive impact on groundwater
yields.
2. Economics and technical feasibility very dependent
on pilot study; however, timing of pilot studies
would not conflict with permit compliance schedules
because outfalls will be required for both Watson-
ville and Santa Cruz.
3. Cost-effectiveness would be enhanced if it were
shown that additional groundwater yield due to
the project was greater than that assumed.
Both the development and screening of reclamation alter-
natives were subjected to scrutiny by government agencies
and the public in general. General layouts, engineering
185
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feasibility analyses and cost estimates were prepared for
all 23 alternatives and an environmental analysis was conducted
by Jones & Stokes Associates (see Table K-l in the Draft
EIS/EIR). A summary of this material was distributed to
public agencies, community and citizen groups and known
interested parties, and on August 10, 1977 a public work-
shop was conducted. The status of the project was discussed
and each of the 2 3 project alternatives was described. The
public was then given a chance to ask questions and suggest
additional approaches to wastewater treatment and disposal.
A summary of the alternatives workshop proceedings was sub-
sequently prepared by Brown and Caldwell and made available
to the BOC and other interested parties. The above listed
reasons for rejection of alternatives were also made available
to agencies and interested public through the project BOC
and IAC.
New or Innovative Alternatives. The Draft EIS/EIR review
process identified one additional alternative for consideration;
this is the use of aquaculture as an advanced waste treatment
technique. At the city's request, Brown and Caldwell researched
this topic. Their findings are the basis for the following
discussion.
A preliminary design and-cost estimate was made for
an aquaculture system patterned after that currently under
construction for the City of Hercules, California. The large
land area requirements preclude use of the site at Nearys
Lagoon; so for this analysis, it was assumed that the treat-
ment plant would be located at the West site. The treat-
ment scheme included the following:
a. A pump station at Nearys Lagoon and force main
to the West site.
b. Treatment processes consisted of communition,
anaerobic ponds, facultative ponds, aquacells,
filtration (optional), chlorination/dechlori-
nation, and composting of water hyacinths.
c. Ocean disposal of effluent via an outfall.
Items a and c above are identical to those proposed
for Alternative OD. . Although it has been suggested that
the effluent from tnis treatment scheme would be suitable
for reclamation, an outfall would still be required 1) to
dispose of winter flows since there is no suitable site for
storage, and 2) to dispose of wastewater in excess of the
demand since local agricultural and landscape irrigation
demand is limited.
186
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There is currently no full-scale, operating treatment
plant of this type, and there is only limited information
available in the literature on which to base design criteria.
Much of the research on water hyacinth treatment has been
conducted in the southeast United States under different
climatic conditions with treatment limited to water hyacinths
only. The system at Hercules, California utilizes several
conventional treatment processes (anaerobic and facultative
ponds) in addition to an aerobic pond integrating floating
macrophytes, microorganisms, protozoa, and invertebrate
detritivores for treatment. This latter treatment scheme
utilizes higher organic loading rates and shorter hydraulic
detention times than the basic water hyacinth treatment and
has only been evaluated during short-term pilot-scale tests.
The aquaculture treatment system proposed for Santa
Cruz was designed for maximum canning week loadings in 1999,
as were the other treatment alternatives. Design criteria
were based on limited published information (S. A. Serfling
and D. Mendola, The Solar Aquacell AWT Lagoon System for the
City of Hercules, California; S. A. Serfling and C. Alsten,
An Integrated, Controlled Environmental Aquaculture Lagoon
Process for Secondary or Advanced Treatment) to maintain
either similar detention times and/or organic loadings for
meeting secondary treatment requirements.
Treatment would consist of communition of raw sewage
at the Nearys Lagoon pump station prior to transport to the
West site. At the West site, raw wastewater would pass through
an upflow anaerobic pond where a large portion of the suspended
solids and approximately 50 percent of the BOD is removed.
The anaerobic ponds would be covered to minimize odors and
to capture usable methane gas. Wastewater then would pass
through facultative ponds covered with a double polyethylene ,
air-inflated roof. Diffused aeration would be provided to
maintain higher dissolved oxygen concentrations for improved
BOD removal. The facultative ponds would contain the Bio-
Web substrate which provides increased surface area for attached
microorganisms. Effluent would then pass into the aerobic
cells which also have the double polyethylene, air-inflated
covers and are equipped with both surface and diffused aerators.
The aerobic cells would contain the floating macrophytes
(water hyacinths and duck weeds) and the Bio-Web substrate.
Final treatment processes would consist of filtration followed
by chlorination/dechlorination. Filtration might be required
to prevent release of nuisance organisms and therefore is
indicated as an optional process.
The total land requirement is 86 acres for the treatment
system plus an additional 30 acres for composting of the
harvested water hyacinths and duck weeds. Plants would be
187
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harvested on a 4-day cycle, chopped, pressed to reduce the
water content, and stored for 3 months in windrows to obtain
a suitable compost. If a suitable market could be found, the
compost could be sold to the public or to local nurseries.
If there is no suitable market for the compost, then an
alternative disposal option might be required for the harvested
plants, such as anaerobic digestion. Since the detention
times necessary for digestion of aquatic plants is much greater
than for sewage sludges, anaerobic digestion would be an
expensive sludge treatment option, and ultimate disposal
at the landfill would be required.
The present worth costs for the aquaculture treatment
system are shown in Table 8 for both capital costs and for
20 years of operation and maintenance. A breakdown in capital
costs is shown in Table 9. The basis for the cost estimate
is the same as used for the other alternatives. A range
in costs is shown for materials and supplies because annual
replacement of the polyethylene pond covers is required,
and there is insufficient data on their purchase and in-
stallation costs. The equivalent cost for the ponds and
the associated appurtenances (covers, Bio-Web substrate,
aeration equipment, etc.) is approximately $380,000 per acre.
This is in good agreement with the estimated cost of $375,000
per acre for a lagoon system to provide secondary treatment
quoted in An Integrated, Controlled Environment Aquaculture
Lagoon Process for Secondary or Advanced Wastewater Treatment,
by S. A. Serfling and C. Alsten. Costs for reclamation of
the effluent are not included in the figures presented in
Tables 8 and 9. Costs for transportation to the reuse site,
storage, distribution, and additional treatment must be added
if reclamation were to be included with this alternative.
Since the treatment scheme does not comply with the Title 22
requirements for unrestricted agricultural use, additional
treatment would have to be provided to conform with these
regulations.
The average annual energy use over the 20 year planning
period is 6.6 million Kwh, excluding the secondary energy
requirements for production of chlorine and sulfur dioxide
from raw materials. Approximately 0.50 of the energy is
for pumping the effluent to the West site with the remaining
energy used for pond aeration, in-plant pumping, and mis-
cellaneous uses.
The total present worth for Alternatives OD and OD.
is $29,600,000 and $44,290,000, respectively. These alter-
natives range from $34 to $50 million less expensive than
the lowest present worth cost for aquaculture treatment shown
in Table 8. Approximately $15 million of the additional
costs for aquaculture treatment is associated with relocation
to the West site and annual replacement of the pond covers.
188
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4
Table 8- Present Worth Cost for
Aquaculture Treatment
Item
Thousand
dollars
Capital
Construction
66,450
Land
1,740
Subtotal
68,190
Operation and Maintenance
Labor
2,890
Materials and supplies
3,110-8,770
Energy
2,200
Chemicals
2,340
Subtotal
10,560-16,220
Total
78,750-84,410
SOURCE: Brown and Caldwell, pers. comm.
189
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5
Table 9. Breakdown of Capital Costs
for Aquaculture Treatment
Description
Present worth,
thousand
dollars
Pump station and transmission line
4 , 360
Treatment facilities
Ponds (includes all costs for lagoon system
and compost operation)
Filters (optional), chlorination/
dechlorination, operations building
28,780
4,100
Site development and construction mobilization
3,320
Demolition of existing plant and relocation of
Scotts Valley line
2,140
Outfall
6,450
Construction contingencies, engineering, legal,
and administration
15,850
Land'
1,740
Sewer system evaluation survey and inflow
correction
1,450
Total
68,190
SOURCE: Brown and Caldwell, pers. comm.
190
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The average primary energy use for Alternatives OD-
and 0D- is 2.3 million and 8.5 million Kwh per year, res-
pectively. The aquaculture treatment alternative uses only
80 percent of the energy required for the secondary treatment
alternative, OD1a; however, it requires almost three times
as much energy 5§ advanced primary treatment, OD7 (Brown
and Caldwell, pers. comm.).
Environmental Implications of Adopting a Nonreclamation
Alternative. Several commentors felt that the indirect impacts
of adopting a nonreclamation alternative deserved further
description. Emphasis was placed on the impacts associated
with development of new water supplies for the Santa Cruz
area. This subject was discussed on pages 389-393 of the
Draft EIS/EIR. The following paragraphs supplement that
discussion.
The proposed Santa Cruz wastewater service area was
expected to generate 6,890 acre-feet of effluent per year
in 1979. By 1999, that total was expected to climb to 11,180
acre-feet. If seasonal reclamation was implemented at the
Santa Cruz plant, about half of that total could be made
available to irrigation reuse schemes during the growing
season. Therefore, a reclamation and reuse project could
theoretically supplement the Santa Cruz area water supply
by about 3,400 acre-feet in 1979 and 5,100 acre-feet in 1999.
This increase in supply is less than the expected increase
in demand due to service area population growth. The Draft
EIS/EIR indicated that water supply demand would probably
increase by about 7,100 acre-feet by 1989 and an additional
7,300 acre-feet by 1999. If winter storage of effluent was
feasible, the reclaimed supply could more closely approximate
the anticipated increase in demand.
If Santa Cruz's effluent is not reclaimed, these anticipated
increases in water demand must be met from other sources
or demand must be reduced through conservation. Development
of new supplies in the Santa Cruz area means either increased
groundwater pumping in the Soquel-Aptos basin or increased
storage and diversion of surface flows. Each of these options
has its own environmental implications. Additional groundwater
pumping could lead to seawater instrusion along the Soquel-
Aptos coastline. There has been no major intrusion in this
area to date, but an extended drought similar to that in
1975-1977 could result in serious degradation of the basin.
This potential exists even without a major increase in drafting
from the groundwater basin. Construction of new surface
storage and diversion facilities would result in a variety
of impacts. The Draft EIS/EIR mentions some of the more
obvious implications, including loss of vegetation and wildlife
habitat through inundation and change in streamflow; increased
191
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silting of stream gravels; change in local aesthetics, and
change in local recreational opportunities. Commentors on
the Draft EIS/EIR pointed out additional impacts, but focused
primarily on costs. Several persons mentioned cost estimates
of $25 million for construction of a dam and reservoir on
Zayante Creek. The source of this cost estimate was not
identified. This cost would be borne locally.
Summary. This discussion should put the indirect impli-
cations of wastewater reclamation into better focus. The
selection of a nonreclamation alternative has been tenta-
tively made by the city because of the limited reuse oppor-
tunities in the immediate Santa Cruz area and the estimated
high cost of treating and transporting wastewater south to
the only sizeable market in the Pajaro Valley. This path
is being followed in spite of strong support for and encouragement
of reclamation by state and local agencies and persons commenting
upon the Draft EIS/EIR. This decision should be made with
the knowledge that local growth is rapidly outstripping
local water supplies and additional water development will
occur at local expense. The city and county have foreseen
some of these potentially adverse implications of growth
and have developed growth management schemes. These efforts
will have to be augmented by capital expenditures for water
development and/or serious efforts to increase water con-
servation. The city's planned ocean disposal of wastewater
postpones any efforts to reuse wastewater, but it will solve
an immediate water quality problem in a cost-effective manner.
Future efforts to reuse wastewater in Santa Cruz will not
be foreclosed by the proposed action, but the time frame
for reclamation will remain indefinite.
192
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BIBLIOGRAPHY
References
Bartle Wells Associates. 1978. Project report, appendix F:
Financial plan and revenue program, Santa Cruz wastewater
facilities planning study.
Brown and Caldwell. 1976d. Summary report - oceanographic
reconnaissance. Oceanographic study reconnaissance phase
report, vol. V, Santa Cruz wastewater facilities planning
study.
1977. Summary - Santa Cruz Oceanographic
Reconnaissance Phase Public Workshop.
1977a. Strategy for wastewater management
alternative formulation.
. 1977e. Santa Cru2 oceanographic predesign
phase report to the Board of Control, November 16, 1977.
1978b. Solid waste study disposal alter-
natives, Santa Cruz wastewater facilities planning study.
1978c. Project report, Santa Cruz waste-
water facilities planning study.
1979. Application for modification of
requirements of secondary treatment; prepared for the City
of Santa Cruz.
California. Department of Parks and Recreation. 1975. California
historical landmarks.
California. Water Resources Control Board. 197 5. Water
quality control plan, central coastal basin (3), parts 1 & 2.
Carmody, F., and J. CollieJr. 1979. Vermicomposting as an
alternative and innovative technology for sludge management.
Bull. Calif. Water Pollution Control Assoc. 16(2): 29.
Jones & Stokes Associates, Inc. 1979. Supplement to the draft
environmental impact report, Santa Cruz wastewater facilities
plan.
Santa Cruz City Energy Management Committee. 1979. Energy
consumption and conservation survey - executive survey.
193
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Santa Cruz County Office of Watershed Management. 1979.
San Lorenzo River watershed management plan.
U.S. Environmental Protection Agency. 1979a. Sludge treatment
and disposal.
U.S. Environmental Protection Agency and City of Santa Cruz.
1979. Draft EIS/EIR, Santa Cruz wastewater facilities plan.
Yoder-Trotter-Orlob & Associates. 1973. Association of Monterey
Bay Area Governments water quality management plan, final report.
Personal Communications
Association of Monterey Bay Area Governments. August 24, 1979.
Telephone conversation with staff.
Brown and Caldwell. November 8, 1979. Letter to Jones & Stokes
Associates, Inc.
November 15, 1979. Telephone conversation
with staff.
December 18, 197 9. Letter to Jones &
Stokes Associates, Inc.
Fiebirling, Wilson. October 12, 197 9. Director of Public Works,
City of Santa Cruz. Letter to Jones & Stokes Associates, Inc.
Freeman, Warren. August 28, 1979. AMBAG staff member. Telephone
conversation.
Hansen, James. August 21, 1979. Monterey Bay Unified Air
Pollution Control District. Telephone conversation.
Thiltgen, Paul. November 21, 1979. Director, Department of
Parks and Recreation, City of Santa Cruz. Telephone
conversation.
194
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LIST OF REPORT PREPARERS
U. S. Environmental Protection Agency
Region IX
William Helphingstine
Jones & Stokes Associates, Inc.
Dr. Charles Hazel
Michael Rushton
Gruen Gruen + Associates
Roberta Mundie
195
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ABBREVIATIONS AND ACRONYMS
ADWF - average dry weather flow
AMBAG - Association of Monterey Bay Area Governments
ARB - California Air Resources Board
BOC - Board of Control
CEQA - California Environmental Quality Act
EIR - Environmental Impact Report
EIS - Environmental Impact Statement
EPA - U. S. Environmental Protection Agency
FWPCA - Federal Water Pollution Control Act
IAC - Interagency Advisory Committee
Kwh - kilowatt hour
MBUAPCD - Monterey Bay Unified Air Pollution Control District
MCTS - Monterey County Transportation Study
MGD - million gallons per day
mg/1 - milligrams per liter
NEPA - National Environmental Policy Act
pphm - parts per hundred million
RWQCB - California Regional Water Quality Control Board
SOPA - Society of Professional Archeologists
SWRCB - California State Water Resources Control Board
196
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Appendix A
PUBLIC HEARING TRANSCRIPT
197
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION IX
215 Fremont Street
San Francisco, California 94105
0O0
JOINT PUBLIC HEARING
by the
US EPA, REGION IX,
and
THE CITY OF SANTA CRUZ
COMBINED DRAFT ENVIRONMENTAL IMPACT STATEMENT-
ENVIRONMENTAL IMPACT REPORT
City Council Chambers
Santa Cruz City Hall
809 Center Street
Santa Cruz, CA 95060
-L9 7 9
7:36 p.m.
Reported by:
THOMAS R. WILSON, CSR, CM
(CSR No. 2052)
Smvthe & Wilson
CERTIFIED SHORTHAND REPORTERS
eai MAPKCT STREET. SUITE IOS5
Sak Fba>jcisco, California P4105
198
S<43-3<94
AREA CODE *IS
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1
2
3
4
5
6
7
8
9
10
11
12
13
14
IS
INDEX
pening Remarks, Chairman Walker 3
tatomont by Mr. William Helphingstine 14
rosentation by Mr. Bob Mills, Brown and Caldwell 19
resentation by Mr. Mike Rushton, Jones & Stokes 46
. L. Cleveland, Shelter Lagoon Association,
132 Shelter Lagoon, Santa Cruz 56
orman S. Lezin, President, Salz Leathers,
Box 1120, Santa Cruz 58
lill Bahn, Leather Workers Local L-122, 1331
River Street, Santa Cruz 62
filliam Paiss, People for Responsible Science,
4567 Opal Criff, Santa Cruz 65
David Bockman, Santa Cruz Regional Group, Sierra
Club, P. O. Box 604, Santa Cruz 72,165
Wallace M. Dale, Santa Cruz Chamber of Commerce,
2200 Delaware Avenue, Santa Cruz 89
William Doyle, University of California Santa
Cruz, Coastal Marine Studies, 173 Hollywood
Avenue, Santa Cruz 92
Ralph Kenworthy, John Inglis Frozen Foods Company,
p. O. Box 3111, Modesto, California 100
Deena Hurwitz, People For A Nuclear Free Environ-
ment, 7915 Empire Grade, Santa Cruz 104
Leon E. Ellis, Teamsters Onion Local 912, P. 0.
Box 591, Watsonville, California 113
Jack Collier, Box 2910, Santa Cruz 114
Diane Livingstone, P. O. Box 2910, Santa Cruz 116
Jane Weed, Energy Action of Santa Cruz,
509 Seaside Street, Santa Cruz 118
Jan Karwin, League of Women Voters, 121 Easterby
Avenue, Santa Cruz 124
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Ronald Pomerantz, Santa Cruz Energy and Urban
Services Task Group, 509 Seaside Street,
Santa Cruz
Glenn Specht, 3070 West Ledyard Way, Aptos,
California
Robert Hall, 107 Post Street, Santa Cruz
Bill Quealy, Santa Cruz Nutrient Energy Action
Committee, 239 Walnut Street, Santa Cruz
Tony Ryals, Nutrient Energy Resources Committee,
875 Fanning Grade, Ben Lomond, California
Jerry Busch, Greenbelt Committee, Environmental
Council Newsletter, Santa Cruz
oOo
HEARING
EXHIBITS
1.
2.
3.
4 .
5.
6.
7.
8.
11.
Pa
127
137
146
151
156
160
Two-page letter. Notice of Intent, over
the signature of Paul De Falco, Jr.,
May 12, 1975
Bound document entitled "Draft EIS/R,
Santa Cruz Wastewater Facilities
Plan," May 1979
Three-page document. Notice of a Joint
Public Hearing, June 26, 1979
One-page document. Proof of Publication,
Santa Cruz Sentinel, July 11, 1979
One-page document. Proof of Publication,
Scotts Valley Banner, July 11, 1979
One-page document. Proof of Publication,
Watsonville Register-Pajaronian ,
July 11, 1979
One-page document, Certificate of
Publication, Green Sheet and Cabrillo
Times, July 11, 1979
Seven-page document, charts used in Mr.
Mills' presentation
12
12
12
13
13
13
13
45
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i i i.
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2
3
4
5
6
7
8
9
10
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12
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14
15
16
17
18
19
20
21
22
23
24
25
HEARING
EXHIBITS (Cont'd)
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
Page
86
86
Document entitled "Why Reclaim Water?"
Document entitled "The Green Solution:
Wastewater Reclamation for Landscape
Irriga tion"
Document entitled "Industrial Water
Recycling" 86
One-page newspaper article entitled
"Hyacinths Thrive on Sewage, Clean
Polluted Water," Los Angeles Times,
April 21, 1976 86
Two-page letter to the 201 Board of
Control from Gary A. Patton,
January 26, 1977, with four-page
attachment 87
One-page memorandum to City Manager from
Director of Parks and Recreation,
August 21, 1979 87
Four-page statement of William Paiss,
August 29, 1979, with three-page
attachment 88
Three-page statement of Ralph Kenworthy 104
Five-page document. Statement of Deena
Hurwitz 112
One-page document. Statement of Jack
Collier 116
Document entitled "Present Value, Con-
structing a Sustainable Future" 118
One-page document. Statement of League
of Women voters of Santa Cruz County 127
Statement of Robert Hall 151
Three-page document entitled "Nutrient
Recycling Greenbelts in Santa Cruz or
Just A Bigger Outfall?" 159
23.
Statement of Tony Ryals
159
the_hearing panel
MATTHEW S. WALKER
Senior Attorney/Hearing Officer
US Environmental Protection Agency
Region IX
215 Fremont Street
San Francisco, California 94105
Chairman
WILLIAM HELPHINGSTINE
Project Officer
US Environmental Protection Agency
Region IX
215 Fremont Street
San Francisco, California 94105
BRUCE VAN ALLEN
Councilmember
City of Santa Cruz
809 Center Street
Santa Cruz, California 95060
WILSON H. FIE
Director of P
City of Santa
809 Center St
Santa Cruz, C
BERLING
ublic Works
Cruz
reet
alifornia 95060
--0O0--
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3
CHAIRMAN WALKER: We will nov go on the
record for this public hearing.
Good evening. My name is Matthew S. Walker,
and I have been designated for purposes of this hear-
ing by the Regional Administrator to be the Hearing
Officer for Region IX of the Environmental Protection
Agency.
Others on the panel today are, on my left,
Mr. Bill Helphingstine, who is the Project Officer for
the project that we are going to discuss tonight.
On my immediate right is Mr. Bruce Van Allen
City Councilman of the City of Santa Cruz.
And on his right is Mr. Wilson H. Fieberling
Director of Public Works of the City of Santa Cruz.
Now, the project that we are going to con-
sider tonight is called for two purposes. A little
while ago off the record, I tried to explain it. I
will try it again. I know this is confusing, and I
hope you will bear with us.
We have two hearings that we are going to
undertake tonight. Very often, when the Environmental
Protection Agency conducts a hearing on an Environ-
mental Impact Statement, the hearing is combined with
a hearing by the state agency, at least in California,
that is required by the California Environmental
4
Quality Act, so:netir,es abbreviated as CE^A. Both the
EPA and the local agency are required to hold public
hearings. The hearings are essentially the same in
most cases. So we combine the hearings, and this save;
a lot of public resources.
Tonight we have a complication. The
Environmental Impact Statement and Report, the com-
bined EIR/EIS, which is this thick book here, contains
project proposals and alternatives that can be con-
sidered by both the Environmental Protection Agency
and the state, and this will be the first inning. We
will conduct the hearing on that report.
There is another report, and this arises
from a complication in the law that I am not sure I
can totally explain, but I'll try.
The last time that Congress amended the
Clean Water Act, they adopted a section that said that,
under certain circumstances, some coastal cities
could get a waiver of a requirement otherwise con-
tained in the Act that everybody attain secondary
treatment. Now, that's a technical term, and I sus-
pect that most of you who have enough interest to come
here understand it, but I'll try very briefly to give
a thumbnail sketch of the difference.
Primary treatment is the first stage of
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5
treatment of municipal sewage. It does a lot of good.
It takes stuff out. Secondary treatment subjects it
to biological action, and this takes even more stuff
out of the sewage so that it can then be discharged
comparatively safely under many circumstances.
There is another stage, called tertiary
treatment, that I don't think is at issue here tonight
That's reserved for places like Lake Tahoe.
Now, if the City of Santa Cruz obtains a
waiver under Section 301(h) of the secondary treatment
requirement, this other alternative can be considered
by EPA in the granting process. At the present time
we cannot consider it because it doesn't meet present
statutes and regulations. It may in the future.
Because it may in the future, in order to save a lot
of resources, we are going to conduct a 'second inning
of this hearing tonight solely on the City's supple-
mentary proposal.
Now, there is still another complication.
This proposal assumes that the City will get a 301(h)
waiver. That is a waiver of the requirement for
secondary treatment. That process is now going on.
The application has been filed. It is being processed
And, unfortunately, the way the regulations are, there
will have to be still a different set of hearings to
determine whether or not the City will or will not get
the 301(h) waiver.
Now, the reason we are doing all of this and
the reason we are having this kind of complication is,
frankly, to try to save some resources so that we don1'
spend the money to have a lot of unnecessary hearings.
It means that, in a sense, we are leapfrogging by
holding a second hearing tonight, a second inning of
this hearing tonight on this supplementary proposal.
Now, that's why we are doing it. We are
trying to save some public money. It does get con-
fusing because the procedures, frankly, are confusing.
We think we have them straight, but I don't blame you
a bit if you don't think you have it straight because
this is kind of that sort of a mess.
Now, we have these registration cards at the
door. We had a segregation of the registration cards
to determine who was going to speak at which inning,
and this, I am told, has been so confusing that I have
just now made up my mind to change the rules. So what
we are going to do now is to take these cards in the
order in which they were presented to the young lady at
the door. She put the time down here and logged them
in. Now, there is a time up in the corner of each of
them when they were handed to her. I will call on
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7
people, when we get to the public part of this session,
in the order in which they were called. If you only
want to talk about the second part of it, you can say,
*1*11 wait until the second inning." If you want to
talk about the subject generally, you should talk at
the first inning because that's the roost general part
of the subject. If you want to talk about whether or
not there should be a Section 301(h) waiver, I won't
stop you right away, but if you start to go on about
the subject and are not talking about these projects,
I nay ask you to wait until we get to that hearing.
And I don't know when or where it's going to be, but I
know that there will have to be one.
Now, if you're only moderately confused now,
I guess I succeeded. So I will make some formal parts
of this statement for the record, that this hearing is
called pursuant to the National Environmental Protect
tion Act, sometimes known as NEPA. I will skip the
legal citations.
It is also called pursuant to the Clean
Hater Act, sometimes known as the Federal Hater
Pollution Control Act. There are federal regulations
which require the Administrator of the EPA, when he is
considering a grant to a municipality, to consider the
possibility of area-wide or regional wastewater
treatment. The purpose of that is so that we don't
have each small community having a separate plant and
duplication of resources.
Now, I tried to explain what the format of
this hearing is going to be. Tonight, after I have
concluded these opening remarks, which I had hoped
would be short, we will call on Mr. Bill Helphingstine,
who is the Project Officer. He will explain the pro-
ject to you.
We will call on the City representatives
for any comments that they may have to make.
We will then call on the engineering con-
sultant, who will explain in somewhat more detail what
this is all about.
We will also call on the environmental con-
sultant to explain in somewhat more detail, although I
hope it will be short, what this is all about.
Then we will call on the public in the way
in which I have indicated in the order that the cards
have been received.
We will then take an intermission after we
have heard from the public for a while; and during the
intermission, these people will be available as
resource persons to you, the audience, for a question-
and-answer session. It's going to be informal, sort of
-------
a low-ring kind of thing, and they will be available
for those questions and answers if you have something
that you just need to ask.
But I must caution you that that question-
and-answer session is not on the record. And if some-
thing is said or you want something said that you are
sure you want to have considered as part of the record
of this hearing and considered by all of these agencies
in making a determination on this project and this
grant, then you should come to the podium during the
time that we are on the record and ask the question or
make your statement.
Now, as to questions, if it's an easy ques-
tion, we may be able to answer it. If it's a hard
question, the likelihood is that we won't because
those of us who are here on the panel, although we
confess to being very wise, are not all wise and we
don't know all the answers. All questions that are
addressed to us on the panel will be addressed in the
final Environmental Impact Statement and Report.
Now, I'll explain very briefly how that
procedure works.
We take in all of the information that you
toll us at the microphone. We will also receive
written documents, either at this hearing or in the
10
next two weeks. We will close the record Uvo weeks
from today. The written statements will be given
every bit as much attention and consideration as the
oral statements because there is a lot of staff work
that goes into this. And, as a matter of fact, a lot
of the staffers do the hard reading and make reports.
You must know that that's the way government works.
After we have concluded hearing from the
public as much as you have to say to us on what I am
calling the first inning, we will then close that one
and open the hearing on the second inning, and that
will be on the supplementary report. During that,
again the consultants will make some statements to
you, and then we will hear from the public.
Now, comments should be made at the podium.
We have certain rules of procedure here that tend to
keep some sense of order, and we need to have you
speak from the microphone. We are not going to
accept questions from the floor, nor are we going to
have cross-examination of either us or the speakers
from the floor. This is an informational meeting. We
are not here to debate the issue; we are here to find
out what you think, and this is what we want to know.
If you have sharp, harsh questions, be sure to ask
them, but we may not be able to provide an answer.
-------
Now, we are making a record of this, as I
mentioned. There is a stenographic shorthand reporter
who is here taking down every word that is said. You
might keep this in mind if your temper rises as to the
kind of comments you are going to make.
A copy of that record will be available in
the Regional Office in due course for public inspec-
tion. If anybody here as an urgent need to have a
copy of his own, you should make individual arrange-
ments with the reporter, who is Mr. Tom Wilson of the
firm of Smythe & Wilson.
If you use the microphone, we wish you to
give us your name, your address and, if you are
representing a group or you want us to consider you as
part of a group, tell us that, too.
We are not placing a time limit on the
speakers, but please do not be repetitive. If you
start repeating yourself several times, we may stop
you.
As I mentioned before, written comments are
requested. It is not necessary for you to read a long
statement at the microphone. You can hand it in, and
it will be given all the attention that the other
statements will receive.
Now, just for the record, I want to note
12
that I have some exhibits here at the desk. Exhibit 1
is a letter which was issued to all interested govern-
ment agencies on May 12th, 1975, by the Regional
Administrator, and that is called the Notice of
Intent and started this procedure.
(Whereupon, Hearing Exhibit
No. 1, two-page letter.
Notice of Intent, over the
signature of Paul De Falco,
Jr. , May 12 , 19 7 5 , was
incorporated into the.
record.)
CHAIRMAN WALKER: Exhibit 2 is the Environ-
mental Impact Statement and Report.
(Whereupon, Hearing Exhibit
No. 2, bound document
entitled "Draft EIS/R, Sant
Cruz Wastewater Facilities
Plan," May 1979, was
incorporated into the
record.)
CHAIRMAN WALKER: Exhibit 3 is the Notice of
Public Hearing that gave notice to the public that we
were going to meet and listen tonight.
(Whereupon, Hearing Exhibit
3, three-page document.
Notice of a Joint Public
Hearino, June 26, 1979, was
incorporated into the
record.)
CHAIRMAN WALKER: Exhibit 4 is an Affidavit
of Publication of that notice in the Santa Cruz
Sentinel.
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(Whereupon, Hearing Exhibit
No. 4, one-page document.
Proof of Publication, Santa
Cruz Sentinel, July 11, 1979
was incorporated into the
record.)
CHAIRMAN WALKER: Exhibit 5 is an Affidavit
of Publication of that notice -- All of these were on
July the 11th, 1979. Let's see. Exhibit 5 is the
affidavit for the Scotts Valley Banner.
(Whereupon, Hearing Exhibit
No. 5, one-page document.
Proof of Publication, The
Scotts Valley Banner, July
11, 1979, was incorporated
into the record.)
CHAIRMAN WALKER: Exhibit 6 is the affidavit
from the Watsonville Register-Pajaronian. Did I get
that right?
MR. VAN ALLEN: Pajaronian.
CHAIRMAN WALKER: Pajaronian.
(Whereupon, Hearing Exhibit
No. 6, one-page document.
Certificate of Publication,
Watsonville Register-
Pajaronian, July 11, 1979,
was incorporated into the
record.)
CHAIRMAN WALKER: And Exhibit 7 is the
Affidavit of Publication in the Green Sheet and
Cabrillo Times.
(Whereupon, Hearing Exhibit
No. 7, one-page document.
Certificate of Publication,
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14
Green Sheet and Cabrillo
Times, July 11, 1979, was
incorporated into the
record.)
CHAIRMAN WALKER: I will not make the supple
ment an exhibit at this time.
Now, I will call on the City for any comment:
that you may wish to make. Sir?
MR. VAN ALLEN: We have no comments right
now.
MR. FIEBERLING: No comments.
CHAIRMAN WALKER: All right. Thank you very
much.
Mr. Helphingstine?
MR. HELPHINGSTINE: Good evening, ladies and
gentlemen. My name is Bill Helphingstine. I'm Projec
Officer for the Environmental Protection Agency, which
has been assigned to this project.
The Environmental Protection Agency and the
City of Santa Cruz have jointly prepared the Environ-
mental Impact Statement and Report, the thick docu-
ment, in order to disclose the impacts of this selecte
project and its alternatives. This project overall
is for the upgrading of the City wastewater treatment
plant to secondary treatment and the construction of a
deep-water ocean outfall.
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15
1
I would like to take this opportunity to
2
mention the water quality problem of the Santa Cruz
3
wastewater treatment plant disposal facilities as well
4
as the purpose of this project and the Draft Environ-
5
mental Impact Statement and Environmental Impact
6
Report.
7
The water quality problem is that the exist-
8
ing wastewater treatment plant and disposal facilities.
9
the existing outfall, don't meet the requirements of
10
the California Regional Water Quality Control Board,
11
Central Coastal Region. That region's discharge per-
12
mit requires that the City of Santa Cruz wastewater
13
treatment plant meet the requirements of the Federal
14
Clean Water Act and the California Ocean Plan.
15
The Clean Water Act requires that waste-
16
waters discharged to the navigable waters of the Unitec
17
States receive a minimum of secondary treatment prior
18
to that discharge. At the moment, the existing City
19
of Santa Cruz wastewater treatment plant provides only
20
primary treatment.
21
The California Ocean Plan requires that
22
pollutants discharged to the ocean shall not exceed
23
certain specified toxic concentrations in the receiv-
24
ing water upon completion of the initial dilution.
25
That's out of the diffuser at the end of the outfall.
16
Pardon me. Some of this is repetitive to
Mr. Walker's comments, but I wish to show the system
and the sequence by which you developed the particular
large document.
The purpose of the project is, then, to
upgrade the existing treat nt plant, the primary, to
provide secondary treatme ^ and to ex. -d the ocean
outfall to a greater depth in order to obtain increase!
dilution of the concentration of toxic pollutants con-
tained in that effluent.
This Environmental Impact Statement and
Report was prepared because we felt significant impact
could result from the implementation of several of the
project alternatives. Those alternatives include —
And this is not in the order of the exact alternatives
but these are the issues and the elements of the
environmental concern — wastewater reclamation for
agricultural irrigation and the creation of a salt-
water intrusion barrier with reused effluent;
Expansion of the existing wastewater treat-
ment plant further into Nearys Lagoon, the existing
site which does happen to be one of the few remaining
coastal lagoons on the California coast;
Construction of a secondary wastewater
treatment plant at a new West Site west of the City of
-------
Santa Cruz;
Construction of a new deeper ocean outfall.
And one thing to remember is a no-action
alternative.
The selected project alternative is named
Alternative 0D1A, Ocean Disposal Alternative 1A of
ocean disposal. It will provide for secondary treat-
ment at Nearys Lagoon and a new ocean outfall for the
wastewaters of the City of Santa Cruz and the County
Sanitation District.
A major impact of this alternative would be
the further filling of approximately three and a half
acres of the perhaps ten acres remaining in the area
of Nearys Lagoon.
Significant impacts would take place if
either of the reclamation alternatives are implemented
The reclamation alternatives could, however, both help
protect the groundwater quality of the Pajaro Valley.
The costs of this project are important.
The present worth capital costs of the major alterna-
tives range from $34 million for the selected alterna-
tive, secondary treatment in Nearys Lagoon with ocean
disposal through a new outfall, to $112 million for
secondary treatment at Nearys Lagoon and new ocean
outfall and agricultural reuse aimed at the Pajaro
18
Valley.
As Mr. Walker pointed out, the Federal Clean
Water Act requires secondary treatment, further treat-
ment than now provided by the city plant. However, the
Clean Water Act now provides in certain circumstances
for a temporary modification of the secondary treatment
requirement. The City of Santa Cruz has applied for a
modification of that secondary treatment requirement,
and that determination will be made sometime in the
future. It's not now determined. If the City is
granted this modification, the City selection of the
recommended project alternative probably will be
changed from Alternative 0D1A, upgrading the Nearys
Lagoon at the new outfall, to the alternative 0D7 ,
which is the subject in detail of the small report,
a separate document by the City. That would provide
advanced primary treatment at Nearys Lagoon, with a
new ocean outfall. With this alternative, there would
be essentially no further expansion into Nearys Lagoon
within a ten-year planning period. Under that, there
may still be some expansion required.
This concludes my comments. Thank you.
CHAIRMAN WALKER: Thank you, Mr.
Helphingstine.
Mr. Bob Mills of the firm of Brown and
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to
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V0
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Caldwell?
MR. MILLS: Thank you.
You will have to take just a minute while I
get this set up without spilling the water, I hope.
Hill you gentlemen be moving around to view
this from the other side?
CHAIRMAN WALKER: Yes.
MR. MILLS: Can everybody see that flip
chart all right?
My name is Bob Mills, and I'm with the
engineering firm of Brown and Caldwell, and we did the
facilities plan for the wastewater facilities improve-
ments for which this EIS/EIR is prepared. So there
will be other documents that I will be referring to,
namely the project report for the wastewater facili-
ties plan, which is another document that is available
in your public library.
I would like to tell you a little bit about
our study, which commenced in the Spring of 1976 and
was done in the, oh, late Summer of 1978, about a year
ago. It was done with a public format, done open to
the public. We had a Board of Control consisting of
elected representatives of both the Cities of
Watsonville, Santa Cruz, and elected public officials
of the County of Santa Cruz and also some
20
representatives, principals of the engineering firm
and the environmental firm, which is Jones i Stokes,
for members of that board as well as some of your key
public employees in the engineering field, such as
Mr. Fieberling and Mr. Porath, the Directors of Public
Works for the city and county.
We also had an Interagency Advisory Committei
made up of representatives of such groups as the
Central Coastal Commission, the Regional Water Quality
Control Board, State Water Quality Control Board, EPA,
other special interest groups who have attended our
meetings also.
In addition, all those meetings were open to
the public and were announced.
I say this so that I want you to be sure that
we didn't prepare this study in a vacuum. We didn't
retreat to our offices and prepare it and come back.
It was done with considerable public input. There weri
26 meetings of the Board of Control/IAC, all open to
the public. In addition, we had two public workshops,
one in August of nineteen-seventy -- No, one in
October of 1976 and one in August of 1977.
Now, tonight you are going to be listening
to a lot of different alternatives, and they all have
catchy little abbreviations. So in order to help you
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try to follow that, this is the nomenclature that we
will be using to describe these alternatives.
"OD" refers to an ocean disposal alternative
through an outfall, deep-water outfall to the ocean.
"RE" refers to a reclamation alternative,
any type of alternative in which some type of reclama-
tion is occurring.
"LD," which you won't hear too much about, is
a land disposal alternative.
And in quite a number of cases, we found that
because of certain seasonal fluctuations in flow, it
was necessary to look at combinations of ocean disposal
and reclamation. So they are OD/RE alternatives.
Lastly, as Mr. Helphingstine mentioned, there
were some "no action" alternatives, which we call
"no project" or "NP" alternatives.
One of the early tasks that we had to look
at was the reclamation potential for this particular
project. It's a very important aspect. I think
probably it's safe to say that the majority of people
here tonight are interested in the cost in the recla-
mation aspects, and I want to talk a little bit about
some of the reclamation possibilities that we looked
at, some of the reclamation potential.
Is there — Is there a market for
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reclamation? Is it viable here?
There are several types of ::ec 1 aTnation that
we considered. The first one would be recharge of a
potable groundwater supply. Recently, there's been
concern that the Soquel Creek area does not have as
much groundwater as once was originally thought. Per-
haps the demand is approaching the safe yield. So
groundwater recharge for a potable water supply is one
that should be considered.
An example of that is the plant down in
Whittier, California. It's been operating since 1962,
where effluent, secondary effluent from the Whittier
Narrows plant and San Jose Creek plant receive advance
waste treatment consisting of coagulation and filtra-
tion followed by chlorine contact for a two-hour
retention time before being recharged down the creek
into some percolation basin.
Now, in that particular project, about 25
percent of the groundwater basin is attained by this
reclamation scheme. However, I'd like to point out
that that started in 1962, and under current State
Department of Health criteria or policy guidelines,
the treatment scheme would have to be changed and they
would have to meet other criteria, which I want to
describe in relation to this project.
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During the course of this project, we were in
contact with State Department of Health officials on
several occasions, and most recently I contacted them
today to get the latest position on the State Depart-
ment of Health concerning direct reclaim of wastewater
to a potable groundwater source. Their position cur-
rently is as follows. This is now a subject of a
draft set of regulations. It's a -- policy guidelines
or a set of draft regulations that hasn't been adopted
yet. But what we are requiring now for this type of
reclamation would be the following.
An effluent from a treatment plant,
essentially of a drinking water quality, carbon
adsorption is mandatory in the treatment scheme. Then
are 20 — They have already 20 chemical constituents
which they are listed that you have to meet with your
effluent. Total organic carbon and chemical oxygen
demands have to be on the level of three or five
milligrams per liter. That's a tremendously tough
discharge requirement to meet. It would probably take
not only carbon adsorption, but some type of
demineralization, such as reverse osmosis to get to
that level.
But the particular effluent we have here in
Santa Cruz, because of the high total dissolved
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solvents or salts, if you will, is so high that some
type of demineralization would have to be done to
reduce that level. So we are talking about a very
expensive treatment scheme.
Secondly, a maximum of only 50 percent of
the water in the reclaimed water basin can be of waste-
water origin, the maximum. So you can't replenish it
all.
Thirdly, you have to have a ten-foot vertica'
aerated zone of ground between the bottom of where you
are percolating the wastewater to the top of the water
aquifer.
And, lastly -- And this is a real different
one for this particular area — the groundwater can't
be used for one year. In other words, you have to
have your aquifer such that the water has to be in the
ground coming down from the recharge area for a year
before you extract it for use. This applies not only
to public water supplies, but to private domestic
drinking wells, if there are any in the area.
Based on those criteria from the State
Department of Health, we advised the City that we
thought it would be extremely impractical to pursue
direct recharge of the groundwater as a viable recla-
mation alternative.
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Today I talked to two representatives of the
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requirements of the EPA and the State Water Resources
State Department of Health concerning that issue, and
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Control Board.
Mr. Richard McMillan, who represents the State
3
I was looking for a piece of blank paper
Department of Health in this area, stated, and I quote.
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there, but 1 guess I don't have one.
"It would be extremely unlikely that the State
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The Federal Environmental Protection Agency
Department of Health would approve of such a project."
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primary purpose here is to protect water quality, to
Not only that, but he said that there must
7
improve water quality. That was the purpose of the
be full redundancy of treatment units. If you are
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Clean Water Act. Their current funding position.
going to reclaim all your wastewater in the drinking
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because of limitations from Congress, are that they
supply, you have to be worried about the quality of
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will only fund to the level of an alternative which
that water at all times. One way to do it would be to
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will accomplish that goal. If there is additional
double up on all the treatment units, but that's not
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work -- If there is additional money to be spent on
acceptable. Some way of getting rid of that waste-
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reclamation but there is an alternative that
water should there be an equipment breakdown must be
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accomplishes cleaning up the waters, they will fund
provided.
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only to the level of the less expensive alternative.
What he's saying is that an outfall would
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That means that you can go ahead with the reclamation
still be needed as a backup in case that system failed.
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alternative, but you would have to pay the difference
That's only one of the hurdles, though.
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all out of the local area. That's another hurdle.
That's only one of the hurdles to that type of a
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The third hurdle is the State Water Resourc
scheme.
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Control Board, who says that they will not fund a
I don't want to rest on this too long, but I
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project for reclamation unless the cost of that
think it's an important issue.
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reclaimed water is less expensive than an alternative
Not only would you have to have approval of
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source. And we will show you some figures here
the State Department of Water Resources, which might
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tonight for wastewater reclamation which don't beat
be difficult to obtain, but you also have the
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that criteria.
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The unsubsidizcd cost of importing water,
say through the San Felipe project, would be on the
order of $200 per acre foot; And you will see tonight
that we have some costs for reclaimed water that are
coming out higher than that because of the quality of
the wastewater that we have to deal with.
Because of all those factors, all those
hurdles, we felt that it was extremely improbable thai
such a project would be funded and, therefore, we did
not recommend that type of reclamation. However, we
did look at a lot of other reclamation schemes and
other types of reclamation potential. The other type:
that we did look at were supporting reclamation for
support of landscaping and parks and that kind of
thing, reclamation for agricultural reuse, which is
covered under Title 22 of the California Administrate
<
Code. He looked at possible stream flow augmentation
and those were the main ones that we looked at.
Some other problems that occurred with that
I'd like to describe just briefly.
Me have here a chart that shows the north
county. Now, this is just in the north, excluding th
Pajaro Valley, the north county demand for water for
certain nonpotable uses.
As you can see, we have agriculture, which
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mainly the Brussels sprouts growing up on the Wc-st
Coast, which requires 5,000 acre feet per year.
Landscaping within the northern areas,
approximately 500.
And industry, this being Lone Star Industrie;
at Davenport, which takes quite a pipeline, by the way,
and Salz Tannery demand about 1,000.
So the total local demand in the north is
quite small. It's about 6500 acre feet per year.
The amount of wastewater produced at the
Santa Cruz plant, according to our study, when the
county sanitation district has all its contributary
area connected, would range from 14,600 in 1979 to
about 25,200 in 1999, much greater than the demand in
this end of the area.
Now, we didn't quit looking at the north en
reclamation schemes, but we did start to turn towards
the Pajaro Valley. The Pajaro Valley, of course, has
had a long history of salt-water intrusion at the
mouth of the river, and there the demand on the ground
water basin is much in excess of the safe yield, so
we looked mainly toward the Pajaro Valley as a means
of reclaiming large amounts of wastewater.
Now, what we did first in the study was to
set up some initial alternatives, and these
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alternatives were based on the main issues of the
study, what we thought the main issues were. Some of
those we considered were the method of disposal.
Should it be disposed of in the ocean? Should it be
disposed of on land? Should all of it be reclaimed?
Should part of it be reclaimed?
Secondly was what about the food processors.
The food processors are an important part of this
community. They do exercise a large BOD loading on
the treatment plant. It might be cheaper for them to
separate and have their own system. We took a look
at that.
Method of treatment. Activated sludge.
Should we go to physical chemical treatment to get it
on a more constrained site basis so it would all fit
into Nearys Lagoon right now?
We looked at the reclamation potential,
which I have just described in some detail.
And, lastly, we took a look at sludge dis-
posal. The important aspect of the treatment is what
do you do with the solids that you take out of waste-
water. It's a critical issue.
Those are-the issues that we addressed, and
we set up an initial array of 23 alternatives. Now,
I would like to read those to you simply so that you
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will know all of the possibilities that we investi-
gated. I won't show you any pictures of them or any-
thing because we will narrow that down to a select few
later on. But the ones that we did look at were 0D1,
which is activated secondary treatment at Nearys
Lagoon with year-round disposal through an ocean out-
fall.
RE1, which was year-round reclamation of all
the wastewater in the Pajaro Valley for reuse.
LD1, which was year-round land disposal up
close to Santa Cruz without any reclamation potential
but no ocean outfall.
Now, OD2 was our look at trickling filters
as opposed to activated sludge, still at Nearys Lagoon
with an ocean disposal. Everything with "OD" is ocean
disposal.
OD3 was our look at physical/chemical treat-
ment in the Nearys Lagoon site.
V7e thought if people are concerned about
encroachment on the lagoon, why don't we separate the
plant or take the plant out. That was 0D4A and B.
0D4A was a split of the plant with the part that's
there now remaining there and the secondary treatment
put across from the Southern Pacific yard -- Southern
Pacific property just next to the railroad yard.
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0D4B was to remove the whole plant
altogether, get it out of Nearys Lagoon, take it up
on the West Site, to get it away from the lagoon area,
which is a park and recreational facility; wildlife
facility, also.
Then we took a look at 0D/LD1, which is a
separation of the food processors, which I already
mentioned.
We took a look at OD/RE1, which is what to
do with Scotts Valley. They had their own consultant.
We were given the task to review his work. We con-
curred on their reclamation scheme, which provides for
reclamation for irrigation of golf courses on the way
down as the flow comes down from their plant toward
Santa Cruz for the golf courses, and maybe the Odd
Fellows Cemetery and some of those types of irriga-
tion reuse, but they are also planning ocean discharge
for the Winter flows. So that's 0D/RE1, and they
intend to use the Santa Cruz outfall for disposal in
the Wintertime. The problem with that is -- is that
your wastewater supply, if this is a typical month,
say, in 1979, and this -- the fiscal year is starting
in July, your supply will tend to increase slightly
in the wet weather months due to infiltration in flow
into the sewer system. At the same time, for
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agricultural reuse and for landscaping and that kind
of thing, the demand drops way down at tho same time.
The problem is that, if you are ijoing to p1 iniinate
ocean disposal, you have got to account for the volume
of water between those two curves and store it some-
where in a reservoir.
So that's one of the problems that Scotts
Valley had, and so they went to ocean disposal of the
wet weather flows in the Winter through the outfall
rather than storage.
I mentioned that the -- that the Santa Cruz
wastewater is high in total dissoved solvents. Santa
Cruz County is a little bit less because they don't
have the tannery. Supposing we separate Santa Cruz
County out, treat that separately and reclaim that
wastewater. That was the subject of 0D/RE2.
Conversely, we went to OD/RE3 where we
separated Salz Tannery out and said what if we treat
Salz Tannery separately and treat the rest of it. If
you take that out, the TDS of Santa Cruz will drop
down close to what it is in Santa Cruz County Sanita-
tion District.
We looked at 0D/RE6, which is the reclama-
tion at Watsonville for pastures and orchards in that
area. One of the problems, as I mentioned, was
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getting the quality of the water, which is expensive,
to a level that you can use it on -- unrestricted on
any type of crop, particularly crops such as lettuce,
which they grow down there, which is picked for humai
consumption raw. However, you could irrigate pasturi
providing you don't pick any fruit off the ground --
I mean orchards and pastures, with a reclamation of
with less stringent quality -- effluent quality
restrictions. We looked at that.
Next we looked at 0D/RE7, which was a salt
water intrusion barrier, using Watsonville effluent.
This is similar to the project that's going on in
Orange County, California, where the factory takes a
very highly treated, advanced waste treated effluent
and discharges it into a salt-water intrusion barrie
which X will explain in a minute, for purposes of
keeping the seawater away from the potable fresh wat
groundwater supply that's being used. We took a loo
at that for the City of Watsonville.
I should explain, I guess, that although v
were not charged to look at Watsonville itself, we
were charged with responsibility of looking at the
potential use of its effluent for reclamation pur-
poses .
0D/RE8 was stream flow augmentation. We
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found that with the major streams here, augmentation
was impractical because of the same recharge of the
groundwater, potable groundwater system that I men-
tioned before. There might be an exception to the
San Lorenzo River below the State Street wells where
you intake to your fresh water supply, but that was
only about three miles in length and proved to be
quite costly for that short span and the amount of
benefits received.
Then we looked at the sludge disposal option?
We looked at anaerobic sludge digestion, and we looked
also at lime stabilization of sludge. The anaerobic
digestion process has the advantage of being able to
take the methane from the digestion process and using
it as fuel.
We looked at NP1, which is absolutely no
project whatsoever, and NP2. We had two no-project
alternatives.
NP2 was a -- where we did nothing with the
treatment plant. But since the Regional Board had
mandated that the outfall be extended, we looked at
no new treatment plant but a new outfall.
By the way, just to keep it clear, presently
the plant has primary treatment, which is essentially
a sedimentation process, chemically assisted, and an
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outfall that's 2,000 feet long, 36 inches in diameter,
discharges to a depth of 52 feet, has an initial
dilution of about 15 to 16 to 1.
The costs of all these alternatives, based
on December, 1976, dollars, because that's when we
did -- started the cost analyses work, so that was our
date, for 20 years of operation, including all the
capital improvements, ranged from $41 million to
$130 million. That's on the first cut.
All right. Those figures aren't exactly
what Nr. Helphingstine told you because we made a
second cut, which I'm going to talk about now.
The cost of reclaimed water on our first
cut ranged from $419 per acre foot to -- $422
Excuse me — per acre foot to $719 per acre foot as
compared to the $200 figure I mentioned before.
Our next step, of course, was to screen thes
down to a manageable few, which we could study in
detail, and that screening process took about four
months. There were several presentations to the Board
of Control. They were quite active in the screening
process. We finally screened them down to the final
five or so that I'm going to describe right now.
The first one was OD1A. Keep in mind now
that -- that all these alternatives that I'm talking
about provide secondary treatment in compliance with
Public Law 92-500.
Here is the existing treatment plant at
Nearys Lagoon. ODl would be providing activated
sludge at Nearys Lagoon with a discharge through the
existing tunnel to the beach, then out through a new
extended ocean outfall. The new outfall ends right
about there -- I mean the existing outfall ends right
about there. Excuse me.
This outfall was designed with several cri-
teria in mind, and it was based on an oceanograpic
study which accompanied our project report work, our
facilities planning work, if you will.
The oceanographic study was quite detailed.
It took into account geotechnical studies of the sub-
marine area, a marine biology reconnaissance phase, a
physical oceanographic phase, which included setting
current meters out there, setting drogues, both free
and tethered, to watch the drift cards, wind monitorii
items such as this. It included a predesigned study
of various outfall, alternate outfall routes, and the
design criteria that we were trying to achieve was th<
following.
First of all, there is what is known as the
California Ocean Plan, which details for you and
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specifies the level of effluent that can be disposed
of through a deep-water outfall. One of the criterias
was that our outfall had to meet the requirements of
the Ocean Plan.
Secondly, we were very concerned about shore
contact, particularly due to the new marine mammals
lab for the University of California Santa Cruz,
located up at Terrace Point, and we wanted to make sure
that we did not impact that influent to their lab with
any detrimental impact, so we needed to keep -- get
enough adequate dilution, subsequent dilution, and
reduce the shore contact-
Thirdly, we wanted to keep the field coming
out of that diffuser submerged -- submerged as much as
possible as often as possible. It's visible some of
the times now, even from the shore, and we wanted to
make sure that, for aesthetic and recreational purposes,
that the field stayed submerged so that floatables
would not be a concern on the water surface, grease,
oil, that kind of thing. Just grease and oil. So we
ended up with the final alternatives.
This outfall here is about 10,000 feet long.
It discharges at an elevation of 100 -- at a depth of
100 feet; has a 2100 foot diffuser on the end of it,
gives us an initial dilution of 160 to 1, ten times
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better than the existing outfall, and it's twice as
good as the requirement of the Ocean Plan for the
toxic constituent that most controls its design, which
is cadmium, I believe.
FROM THE FLOOR: Chroniuu.
MR. MILLS: Pardon me. Chromium.
We had two alternatives here at the plant,
and I am going to need some assistance now probably
with lights and maybe also with pushing this thing.
(Slide No. 1.)
Here's the — Can everybody see that with
the lights on? Let's try it.
There is the plant as it exists today at
Nearys Lagoon.
(Slide No. 2.)
1 think it might be helpful if that -- This
is 0D1A. It's activated sludge treatment at Nearys
Lagoon. And this uses the pure oxygen process. The
pure oxygen process converts air to oxygen, air being
only one-fifth oxygen. This provides essentially pure
oxygen, which is put into the aeration tanks. In this
case, they are called oxidation tanks. My boss always
tells me they are oxidation tanks when it's an oxygen-
activated sludge.
Then, by the way, these units that are in
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•lots and dashes are the existing facilities which you
s.iw in the previous aerial photo, so those are now.
Here's the berm. You can see the impact of the
facilities into the berm, particularly over here where
the secondary sed tanks, part of the secondary pro-
cess are located.
Now, these, this what you see here, would be
good for 20 years. It's good through the end of the
century. We have a 20-year planning period that we
are talking about. Then it would go out this far at
the end of Stage 1 construction, which would be pro-
posed now.
Would you change the slide, please.
(Slide No. 3.)
And is there any better focus I can get?
This is 0D1B. The difference here is that
we are using air instead of oxygen. You can see how
much bigger that reactor became because, when we got
rid of the air and — got rid of the oxygen and used
the air, so we replaced that oxygen-generating station
with a regular blower built in. It contains blowers
that blow air into the sewer here. This is an aerobic
process, which means that the bugs need to have air in
order to work on the sludge. Same type of secondary
sed tanks, but you can see the impact is much greater
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outside the berm.
All ridht. I.iyhts. You can just leave that
on .
Next we talked about moving the site. We
felt that the issue of Nearys Lagoon was important
enough that we would want to take a closer look at
moving the site. That's Alternative 0D4B. This is
the site that we proposed, which was up right near the
old Walti Schilling plant with -- It would take --
What it means would be that this plant would be
abandoned. It would be demolished. And in its place
would be a raw sewage pump station, hopefully of low
profile, maybe underground. It would pump raw sewage
out this pipeline to this site, where it would receive
air activated sludge treatment, secondary treatment
and ocean disposal through an outfall that, as you can
see, ends up at approximately the same point and it is
at the same depth, to provide disposal of effluent to
the ocean year-round.
(Slide No. 4.)
This is what that would look like.
Larry, can you get those lights?
This is turned on its side, north pointing
to the right instead of up. In other words, this is
Highway 1 up here; this is the Southern Pacific
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Railroad there, and here's raw sewage coming in. Now
we have a brand-new primary treatment plant plus we
got rid of the one at Nearys Lagoon, and aeration
tanks up here, with a blower building here. We didn't
consider it necessary to consider oxygen here, and
there is plenty of land available, and oxygen per se
would be more expensive in this kind of a situation.
Secondary sed tanks, chlorine contact and
disposal out through the outfall with anaerobic
digesters here. These are sludge thickeners for the
sludge prior to entrance into the digester.
That was 0D4B.
Now, we took a look at some more reclamation
alternatives- All right. Larry.
As I mentioned, we did look at some local
reclamation parks in thei city, Brussels sprouts to the
north, but the ones that we thought were most viable
that had the lowest reclaimed water costs were the ones
that went to the Pajaro. We keep the secondary treat-
ment plant here with an ocean disposal because of the
problem with the Winter discharge that I mentioned.
We pump secondary effluent along a pipeline. By that
time, our pressure -- our pressure in the pipe is so
high at this point that we have to repump there, and
we continue south to a point approximately opposite the
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military academy, which is on a hill, agricultural
land use. And then we stopped there. The reason we
stop at the high point is because now we can dis-
tribute to the agricultural area by gravity without
any pumping.
So we get to the highest containable head,
and we treat -- provide tertiary treatment, advance
waste treatment for our -- for a portion of our
effluent there for agricultural reuse.
We looked at two alternatives here: 0D5A,
which just was Santa Cruz effluent; 0D5B, including
bringing in Watsonville.
(S1ide No. 5.)
This is a schematic of the advance waste
treatment plant that would appear on the hill there.
We have a flow equalization reservoir in the back, anc
we have the advance waste treatment facilities in the
front there. They consist of filtration/demineraliza-
tion because we have that high TDS content.
By the way, I mentioned this, the TDS. I
hope I did have Santa Cruz on the order of 1100 milli-
grams per liter. The farmers like to get it around
300 milligrams per liter, and they will settle for
about 500 milligrams per liter. What we do here is
we take off a portion of the flow and deminera1ize it
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clown to nothing and mix it back in with the rest of
the flow so we avoid the big expense of demineralizing
all of the flow, and then we provide chlorination at
this point with the two-hour detention time. This
process is identical to the one that they use at
Whittier. That would treat your wastewater to such an
extent that it could be used for agricultural reuse on
any crop.
So we were able to take the area that's the
prime agricultural land and schematically show some
distribution lines there.
The last one that we looked at in detail was
0D/RE7, which was the salt water intrusion barrier
using reclaimed effluent from Watsonville. The
Hatsonville plant is here. He would treat this to a
high tertiary level and inject it in a row of wells
along the mouth of the Pajaro River. Then we would
pull it back up in the back with some extraction wells
It works essentially like this. You pump in
and you pull out behind. That makes a barrier there
so the salt water can't come into the groundwater
basin.
Those are the ones that we looked at. Here
is the capital costs. This is in 1976 dollars for
20 years. It includes operation and maintenance as
wo 11 as capital costs.
You find that -- Forget that one because we
can't talk about it right now. That's 0D1A is
$44 million.
ODIB, $46.
OD4B, $60 million.
OD/RE5A, 109.
OD/RESB, 136.
And OD/RE7, 91.
What does that mean in the cost of the
reclaimed water? If you take -- This is just the cost
of reclaimed water. If you take that and compare it
against the annual volume that you intend to reclaim,
we see that OD/RE5 costs about $767 per acre foot;
$709 for 5B; $318 for OD/RE7. That's beginning to get
down there where it might be feasible.
I'm getting messages that I'm talking way toe
long, so I think I will just close by saying that,
based on the requirement, the secondary -- for secon-
dary treatment, we felt that OD1A was the best apparent
alternative. It was the lowest cost to meet that
requirement. Let me get my cost page out. $44 niillior
It would cost an extra $16 million to move the plant
out of the lagoon. And we thought that it would not
take up any agricultural land on the west site; there
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would no — there would be no need for high energy
consumption to pump all the wastewater up there; it
had less of an impact on the lagoon than Alternate
IB, and it was close to the Pajaro Valley, so that if
you ever did find a market to reclaim it, you were
closer than you would be at the West Site. So that
was primarily our recommendation there.
We also thought that we were getting OD/RE7
down in price as to reclaimed water that that deserves
further study and analysis, so we recommended that
that occur.
Thank you.
CHAIRMAN WALKER: Thank you.
I have been handed copies of some of the
documents that were shown on the flip charts, and for
purposes of the record, they will be made Exhibit 8 in
this record.
(Whereupon, Hearing Exhibit
No. 8, seven-page document,
charts used in Mr. Mills'
presentation, was incor-
porated into the record.)
CHAIRMAN WALKER: The slides and the other
maps, I take it, are already in the Environmental
Impact Report?
MR. MILLS: They are in the project report.
CHAIRMAN WALKER: In the project report.
4 6
MR. MILLS: You are technically correct.
CHAIRMAN WALKER: Thank you.
We will next hear from Mr. Mike Rushton of
the firm of Jones & Stokes and Associates. And, Mr.
Rushton, I remind you that we are here to hear the
people, not the introducers.
MR. RUSHTON: Thank you. I will try to keep
my presentation as brief as possible.
My name is Mike Rushton. I'm with the firm
of Jones & Stokes Associates. We prepared the
Environmental Impact Statement and Report for the EPA
and the City of Santa Cruz, and we also prepared the
supplement, which we will talk about in the second
phase of this hearing.
Briefly what I'll be showing you are several
lists of impacts that we determined after studying
the refined list of alternatives that were just talked
about by Mr. Mills.
And, basically, there were four action
alternatives and two no-project alternatives. I say
four in that we combined for tonight's presentation
the impact of the 0D1A/1B sub options and the 0D/RE5A
and 5B sub options, so I'm really going to show you
four action and two no-action alternatives.
In our report, we generally talk about both
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construction, operation and secondary impacts of each
of these alternatives, and my format tonight will be
in that order.
First, I'm going to discuss some of the
impacts that are common to each of these action
alternatives, and these are primarily growth, the
growth implications of the alternatives. Our growth
analysis was based on the populations that were used
to size the treatment facilities by Brown and Caldwell.
These numbers were prepared by Gruen Gruen + Associates
a subcontractor in our effort. They were prepared
specifically for the Santa Cruz facility. And that
facility plan and currently the plant here at Santa
Cruz is sized for about 21,000,000 gallons per day of
primary treatment. And the current flows are around
12 to 13 million gallons per day.
So you can see that there is an excess of
capacity currently for primary treatment.
The population projections prepared by
Gruen Gruen + Associates, when compared to the numbers
prepared at the same time by the State Water Resources
Control Board for this service area was slightly lower
The planning numbers are slightly lower than the State
Board numbers developed for the service area.
Because there is already capacity in the
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system for growth in the Santa Cruz area, we felt that
the treatment plant and the proposed secondary treat-
ment alternatives did not warrant a growth-inducing
label. These facilities would be constructed to
accommodate the populations that are planned for the
area. And, therefore, we didn't want to label the
system "growth-inducing."
I think that in the process of designing
these facilities in the future, the population pro-
jections may undergo some modification because addi-
tional population projections have been prepared for
the area in the 208 planning efforts in Santa Cruz and
Monterey Counties. 208 is another section of the
Clean Water Act that provides for area-wide water
management planning.
What I have got here on my first chart are
basically the numbers used and the forecasts prepared
for these service areas, which includes the Santa Cruz,
Capitola, Soquel, Aptos areas and as far down as
La Selva Beach. It does not include Scotts Valley.
Scotts Valley was considered only for wastewater dis-
charge through the outfall, not for treatment.
The forecast proposed a service area popula-
tion of 130,000 in 197$, and the numbers used to size
the facilities for the ten-year planning period.
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175,500, or roughly a 45,000 person increase in the
service area. The 1999 service area forecast, 221,000
or about a 91,000 increase in the service area.
Now, what this meant to us in our analysis
was that there were certain impacts that would occur
from this type of growth in the service area. The
things that we focused on in the report were conver-
sion of ag land in the area, a nonrenewable resource.
We were concerned mainly with what the growth implica-
tions were for ag land west of Santa Cruz and in the
La Selva Beach area where there are prime agricultural
lands presently being used.
We also looked at encroachment on coastal
wetlands and riparian areas. They have extreme value
for wildlife habitats and recreational and aesthetic
purposes.
We also looked at what the increase in
population meant in terms of increasing demand for
public services, typical services: police, fire
protection, schools, solid waste and power.
One of the more important secondary impacts
was what it meant in terms of increased demand for
water. Based on the population numbers that I talked
about up here, we show that in the -- at the end of
the ten-year planning period, that population would
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generate in residential terms -- This is just resi-
dential water use now -- approximately a seven-thousanc
acre foot increase from what was currently ^being needec
at the 1976 population level.
By 1999, the total increase would be 14,300.
This is in acre feet.
And according to our information and
information prepared in the facility plan, this was
roughly 5,000 acre feet in excess of the developed
water supply that was available in the year 1975.
Also, a secondary impact of all these
action alternatives is increasing air pollution, air
pollutant emissions. You may be familiar with the
fact that the Santa Cruz and Monterey County areas
are labeled a nonattainment area for oxidant according
to national ambient air quality standards prepared by
the federal government. This means basically that
oxidant levels, ambient oxidant levels, are in excess
of the federal standard. There's recently been a
reduction in the federal standards, but the projec-
tions that were prepared in our report indicate that
that will continue to be the case: that we will be
in violation in this area of the oxidant standard.
The date for achieving the attainment or
attaining the standard is currently unknown, and
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AMBAG is now in the process of doing additional work
on preparing a plan to meet those federal standards.
This will require cooperation both by the city and
county to develop means of reducing oxidant levels.
Other impacts, quickly, that are common to
the action alternatives. Each of these action
alternatives labeled up here would remove the aesthetic
and public health problems associated with the present
discharge that was described earlier, and each would
be capable of complying with jState Ocean Plan and
Federal Clean Hater Ret standards.
Now, I am going to go on through some more
specific impacts, specific to the alternatives.
Alternative ODl was the continued secondary
treatment in Nearys Lagoon. In the construction
phase, as mentioned earlier, this would require
removal of three and a half to five and a half acres oi
the Nearys Lagoon wetlands, whether you want air-
activated or water-activated sludge treatment.
The outfall proposed for construction would
require approximately 10,000 linear feet of sandy
bottom habitat off the coast of Santa Cruz.
In the operation phase of 001, there would
be no water available for reuse in the county. And
these are just lists of the major impacts that we
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describe in our report.
Continued use of Nearys Lagoon as a treat-
ment location, continued plant-site/land use conflicts
This is odors, conflicts between wastewater treatment
facilities and nearby recreational or residential land
uses.
ODl has a low chemical and energy requiremen
in comparison to the other alternatives that I'm
describing here, and it also has the lowest cost of
any of the action alternatives, as Mr. Mills discussed
earlier.
Alternative 0D4B is moving a secondary treat
ment facility to the West Site in the construction
phase. You would be removing 17 acres of agricultural
land out there for the treatment plant. You would be
placing an outfall across 5,000 to 8,500 linear feet o
both sandy bottom and discontinuous rocky bottom habi-
tats off the coast immediately south of the treatment
plant in the Terrace Point area, and it would require
excavation for this pipeline in the steep bluffs that
are present in that part of the coastline. This is
construction impact.
In the operation phase, this alternative
again has no water reuse element. It does remove the
plant from the Nearys Lagoon site. There may be some
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additional growth stimulation from the location in that
area based on the fact that the interceptor that now
serves that part of the city is restricting growth in
that area. It has a moderate energy and low chemical
requirement compared to the other alternatives. It
does have a visual conflict because it's located shore
ward of Highway 1 in the coastal corridor, and it has a
present worth cost of about 15.5 million more than
Alternative 0D1.
0D/RE5 is the reclamation alternative, the
large reclamation system for reuse of agriculture in
the Pajaro Valley. It includes an ODl type treatment
for the Santa Cruz water initially before it's pumped
southward.
In the construction phase, it would have the
same impacts obviously as ODl. This is further
encroachment in Nearys Lagoon.
I hope I don't have to use this again.
It would remove 45 acres of agricultural
land for the tertiary facilities in the Watsonville
area.
The construction of the pipeline down there
would have to cross Rodeo and Soquel creeks, Arana
Gulch and Schwanns Lagoon, causing loss of riparian
habitat through construction. And it would also
5 4
require pipeline construction on a road bod that
passes through the designated protection zone for the
long-toed salamander, a rare species. And the con-
struction obviously would have to be kept on the road-
way to avoid any impact to that particular rare
species.
Operationally, this alternative provides for
16,700 acre feet of reclaimed water in the year 1999
for crop use. The treatment plant would remain in
Nearys Lagoon, secondary plant. The irrigation opera-
tion would have a potential for soil, groundwater and
surface water degradation, depending on how the thing
was operated. You would have to set up some pretty
strict operational procedures to avoid salt build-up
in the soil, leaching of salts to the groundwater and
similar type impacts. It would provide a nutrient
source for crops in the form of nitrogen and phos-
phorous. It would have a high chemical and energy
requirement, and it has a present worth cost of about
$65 million more than ODl.
Alternative 0D/RE7 is the reclamation scheme
That's an injection well in the mouth of the Pajaro
River for salt water intrusion protection. It also
includes an OD element for the City of Santa Cruz and
its immediate service area for the wet weather season.
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and the location of that plant would be flexible. It
could be an OD4B or an OD1 option.
In the construction phase, it would have the
same impacts as 0D1 and 0D4B. It would remove 14 acre
for the tertiary facility near the existing Watsonvill
plant, and there will be some riparian loss during con
struction of the well system as it crosses both the
Pajaro River and the Watsonville Slough near the coast
line.
Operationally, again it would require 0D1 or
OD4B type operation impacts. It would provide 12,200
acre feet of reclaimed water for the injection barrier
by the year 1999. There would be some potential for
groundwater contamination with this system, depending
on the subsurface hydrology and how well again the
system is operated to protect the existing groundwater
supply in the Pajaro Valley. It has a high chemical
and energy requirement, and it has a present worth
cost of about $46 million more than ODl.
And that concludes my presentation.
CHAIRMAN WALKER: Thank you, sir.
Now, it's your turn. We came here to hear
the public. And as previously announced, we are now
going to call on the members of the public in the
order in which they have signed these little cards.
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In a few minutes, when we get a little farther down,
we will have a departure from that by somebody who is
representing a group. But for the present time, we
will next call on Mr. D. L% Cleveland. Would you try
to get the microphone pointing at your mouth.
MR. D. L. CLEVELAND: My name is Donald
Cleveland.
CHAIRMAN WALKER: Thank you, sir.
MR. CLEVELAND: I live — I'm the Manager of
the Shelter Lagoon Homeowners Association. I live on
Nearys Lagoon where I can see, hear and smell the
treating plant.
As qualifications for what I have to say, I
would point out that 25 years ago, I designed the
treating facilities for a major oil refinery to be
built on Puget Sound where the water had to be so
pure that it did not affect the oysters. That plant
has operated successfully ever since then.
After that, I operated a refinery in Texas,
which ran entirely on treated sewage, secondary
treated only.
As a -- As a resident of Shelter Lagoon, I
would point out that the fact that you have Nearys
Lagoon as a wildlife preserve is through the efforts
of the Fluor Corporation that built Cypress Point
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Apartments and built Shelter Lagoon condominiums, and
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Shelter Lagoon are opposed to any further expansion of
it was their work that dredged out the lagoon and made
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the treatment facilities at the present location.
it possible to be a good wildlife refuge. We would
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Thank you.
hate to see that spoiled.
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CHAIRMAN WALKER: Thank you, sir.
I would be opposed to any extension of the
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The next card that I have is Mr. Norman S.
present plant. We are getting by the way it is. It
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Le zin.
isn't too obnoxious, but we would certainly be
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MR. NORMAN S. LEZIN: Mr. Walker, can you
objected -- we would certainly object to any further
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hear me all right?
expansion there.
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CHAIRMAN WALKER: Yes. Thank you.
There was one point that was not brought up.
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MR. LEZIN: Fine. My name is Norman Lezin.
and that was the possibility of staying there with your
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I am the President of Salz Leathers. We employ over
first primary treatment and then moving up in the West
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300 people here in Santa Cruz, and we've been there as
Site for just the secondary treatment. I would ques-
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a tannery about 120 years. We tan about 1800 hides a
tion Mr. Mills on one statement that he made about the
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day, and this leather goes into boots, shoes, hiking
possibility of oil and things out in the water. A
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boots, children's shoes, cowboy boots sold throughout
properly designed and operated secondary treatment
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the United States, Mexico, the Orient and now Europe.
plant would never allow any oil to get out into the
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In the last ten years, we have invested over
ocean.
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a million dollars in facilities to treat our effluent,
I would question the need to go out as far as
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handle our waste. We have tried to stay even with or
they do, but certainly that is — may be beyond my
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ahead of the codes as they come up, and it's a tough,
expertise to decide how far out to go. But certainly
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tough battle because you are more ingenious than we
if we are getting by the way we are now and you put in
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secondary treatment, you can't be any worse off than
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We find that, in reviewing the alternatives
what you are now as far as the ocean is concerned.
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presented to us here, that the additional costs are
And I would like to close by saying we at
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particularly cruel and cause us a great deal of
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difficulty because wo are in a very close maryin
industry against a great deal of competition, both in
Lhis country ns wotl as abroad. And oven thouqh I'm
sure you have heard this many, many times, it's still
a fact of life that all of us in our daily existence,
whether it's running a tannery or making any other
economic decision, have to weigh benefits versus costs
And as we look at the costs anticipated and projected
by the consultants who prepared the alternatives, we
are looking at costs that face us with the necessity
of — a bleak one, of either closing up that portion of
the facility that contributes to the treatment cost
and employs about half of our people, and moving it to
another state where conditions are more hospitable.
And we have been invited into Texas and Oklahoma,
which perhaps operate under a different set of restric-
tions, or closing up entirely, which is a prospect that
other plants have faced, namely Legallet Tannery in Sar
Francisco, where they didn't make the investment that-
we have made over the last ten years, when they could-
n't handle current restrictions and come up with the
additional costs of burdens placed on them.
We employ workers, sir, in this area, and
they are producers. They work for us all year long.
They are not out picking up tiles. They are making
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good pay.
We employ people with a variety of back-
grounds, nil the way from rj r .11 e school ;ilumni who
wish to stay in Santa Cruz and can't find good jobs
here and work for us and decide it's a pretty good
place to work, down to ordinary people, people who are
former agricultural workers who want to work all year
long and make a decent income. We employ blacks,
Hispanics. We employ a variety of people. It looks
like the United Nations. We got our first Chinese
just recently. We feel pretty proud of that.
I think you have to recognize, as I am sure
you do, what the impact of these moves are economically
Now, in all my reading of the impact report
and all my visits to the people who are experts in the
field -- I have heard, of course, what you said
tonight, sir, that this was mandated on us because of
certain rules and regulations, and they have slipped
over them very quickly, but I find very little evidence
coming out of Washington, very little evidence coining
out of San Francisco, very little evidence of any kind
that I have ever been able to detect that one alterna-
tive versus another has an effect on the marine life,
which I presume we are concerned with; on the flora
and the fauna and the conditions in the ocean. I sail
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over that area a lot. I'm out there a great deal.
That's the wind-swept Pacific Ocean. That's not
Lake Erie. It's not the Delaware Basin. It's not an
estuary off of Portland, Maine. And yet it seems to
be included in the same general set of regulations
because it's a big country and a complex problem and
difficult to make fine gradations.
I can only tell you that we have faced
problems in the past, and we face this one also, but
we reach the point in a faltering economy with thin
or nonexistent profit margins when we must face up to
the tough decision of whether we can continue to carry
these burdens. The problem we have -- And it's a
problem, I suppose, faced by all industry to one
extent or another -- is that we have got to make our-
selves more productive, more capable of being economic
entities that are viable. We are not part of the
government. He don't get any subsidies. We are not
Chrysler. We are not employed by some federal or
state agency. We got to make it ourselves. And what
you are discussing here is a very real issue for a lot
of people, including myself.
Thank you, sir.
CHAIRMAN WALKER: Thank you, Mr. Lezin.
The next card is Mr. Dill Bahn.
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MR. BILL BAHN: Gentlemen, my name is Bill
Bahn. I live at 1331 River Street. I am the Secretary
Treasurer of Leather Workers Local L-122 of the United
Food and Commercial Workers International.
We have 235 members who work at Salz Leathers
All but two of our members live in Santa Cruz County.
The average worker has about eight years of seniority
at the tannery and makes about $7.50 an hour.
As Mr. Lezin pointed out, the leather
industry is highly competitive, both on a national and
international level. And the competitive ability of
American tanners is being seriously threatened by two
particular issues. One is the unrestricted export of
hides, which you gentlemen had nothing to do with, but
which the federal government has had lots to do with,
and are making a difficult situation for us.
The other is the cost of water treatment.
Now, as Mr. Mills pointed out, Salz Leathers
is one of the primary concerns in virtually all of the
alternatives presented because of the high salt con-
tent of the effluent. I personally am not a biologist
or an economist or an environmentalist or anything,
or have had any kind of training that would qualify
me to speak to any of the alternatives. I'm only a
leather worker who lives in Santa Cruz and am concerne
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about the community and concerned about my job and con-
cerned about representing the people who are in my
union.
Recently our union finished negotiations with
Salz Leathers, and I'm sure that most of you are
familiar with the term of brinkmanship, where you push
as hard as you can, hoping that you don't push the
other party over the brink. Hell, the tanning indus-
tries, Sals Leathers and the members of our union are
approaching the brink. There is not a whole lot of
money left to operate the type of operation that the
tannery has. And the increased costs make it non-
viable.
I'm sure you have also heard about the con-
cern of all American labor about the exporting of jobs,
shoe jobs being exported to Korea or to Taiwan, the
clothing industry jobs to the same countries. Right
now the" leather industry is being exported to foreign
countries. The hides go and there go the jobs of
American tannery workers.
What we seem to be doing also is exporting
our wastes. It's not simply the jobs that go to
Korea or go to Taiwan; it's also the waste. It's all
the things that we produce, all the effluent that we
produce. Now it's produced somewhere else. But we
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still buy the leather. All of us still wear leather
shoes. We all have leather belts. We all like leather
coats. We still like the products that leather pro-
duces .
And it seems to me somehow morally bankrupt
for us to demand that our environment be as clean as it
can be and, at the same time, refuse to pay the social
and economic costs and put those burdens on another
group of people somewhere else in the world and still
derive the benefits.
It seems to me also that a human environment
without good-paying productive jobs for the vast
majority of citizens that live in it is economically
counterproductive, socially destructive and spirtually
ster ile.
I'm not trying to say that we don't need to
have the water treatment. I'm not trying to say that
we don't need to upgrade as much as is possible the
treatment of waste and sewage disposal in this par-
ticular community and in all communities. What I am
saying is that we have to measure the economic cost,
the social costs, of those particular alternatives
against the benefits that we hope to derive.
Thank you.
CHAIRMAN WALKER: Thank you, Mr. Bahn.
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Now, I have somewhat of a problem. The next
card was Mr. Dave Bockman, but I am advised that a Mr.
William Paiss —
MR. WILLIAM PAISS: Paiss.
CHAIRMAN WALKER: -- is the leader of some
group here and prefers to speak ahead --
MR. DAVE BOCKMAN: That's fine.
CHAIRMAN WALKER: Is this agreeable with Mr.
Bockman?
MR. BOCKMAN: Yes.
CHAIRMAN WALKER: What we are going to do,
then, I will call on Mr. Paiss at this time, and then
thereafter we will take the cards in the order in
which they were sent up to me. This isn't exactly the
same order as you have on your list. It's quite unfai
to the other people to take your list as a unit. Ther<:
are quite a lot of cards here, so we will do that.
Mr. Paiss?
MR. PAISS: Thank you.
My name is William Paiss, and I live at
4567 Opal Cliff.
Just some minor background on myself. I'm a
senior in biology at the University, and I'm cur-
rently working on a senior thesis which has to do with
alternate wastewater technology.
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Many present tonight realize the topic of
wastewater treatment is not a single issue, but only
an integral component of this country's energy resourc
system. The question of sewage treatment is directly
connected with issues of population growth, water con-
sumption, energy and land use. a failure to recognize
these connections results in the creation of many
problems, while temporarily solving only one. In fact
it is energetically impossible for us to really solve
the current sewage situation by pushing it further out
to sea and complicating it with more chemicals and
high technology.
As our past State Senator John Tunney
stated, "The experience of the last 50 years should
have brought home the lesson that as problems become
more complex, the required technological solutions
become more complex and expensive."
The answer is not in more technology. A
real solution that will not become obsolete in 20
years requires a reevaluation of our long-term goals
and objectives.
A friend of mine once said, "Once vision is
restricted, then reality is restricted." Many people
here tonight share a common vision for the future of
Santa Cruz which is in complete contrast to the
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proposed plans of Brown and Caldwell. So you can
fully understand the vision we hold, I would like to
begin with a revolutionary assumption. I quote
California's previous State Architect Sim Van Der Ryn.
"Nature admits no waste. Nothing is left
over; everything is joined in the spiral of life. Per-
haps other cultures know this better than we, for they
have no concept of, no word for, waste."
Wendell Berry, author of "The Unsettling of
America," states, "When waste is used, a liability
becomes an asset, and the very concept of waste dis-
appears. "
It is in this concept of waste where our
vision radically departs from conventional thinking.
We regard this entire topic not as wastewater treat-
ment but, instead, as resource management. We realize
our feces and urine are valuable resources badly needed
in a time of increasing prices and decreasing reserves
These minerals and nutrients belong back on the land
from where they came instead of poured into the ocean.
This kind of linear flow from mines to
fields to ocean has had a tremendous effect in areas
we are not usually aware. For example, in the years
since World War II, the production of fertilizer
nitrogen has increased 25 times over food production
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over the same time. Treatment methods of the kind
which Brown and Caldwell suggest and the Draft EIS/EIR
condone will only increase this trend ana make problem
worse.
Now is the time to stop and consider the
long-range effects of our current actions and plan wit!
the health and prosperity of future generations in
mind. Our vision, of which mineral and nutrient
recycling is but one part, could transforn Santa Cruz
into an energy self-sufficient county.
Many of the speakers giving testimony this
evening will not be disagreeing with the content of
the original study or to the EIS/EIR but, instead, to
its limitations and exclusions. I would like to com-
ment on one treatment method not included in any of
the planning studies. It does not require high tech-
nology, large quantities of chemicals, and is less
expensive than conventional systems. When Brown and
Caldwell were asked why they did not include this
kind of treatment in their studies, their reply to
Mr. Fieberling, Director of Public Works, was the
following. I will only read a very small portion of
this letter.
"One of the major reasons the use of water
hyacinths was not seriously considered is that
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the State Wntur Resources Control Board luis
refused to grant such a project other than on a
pilot study basis. The tight time schedule
imposed on the City of Santa Cruz by the Regional
Water Quality Control Board prohibits the employ-
ment of a time-consuming pilot study. The
SWRCB's position is well taken'since the water
hyacinth flourishes in the warm, semitropical
climate of the southeast United States, princi-
pally Louisiana and Florida. The behavior and
productivity of the plants would be subject to
question in the cooler marine climate of Santa
Cruz, and if they are to take a role in protect-
ing public health, their effectiveness must be
analyzed."
I have before me another letter from a firm
called Solar Aquasystems, Incorporated, who specialize
in wastewater reclamation by controlled environment,
ecological process. This company is currently con-
structing a municipal wastewater facility for the
City of Hercules in Northern California.
I would like to read a short summary of the
benefits Solar Aquacell Wastewater Reclamation process
can provide and give some comparisons to proposed
f acilities.
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First is energy use. Solar Aqu.icell uses
ono-half to ono-lourth the operating expense, with
energy costs cjreatly reduced through solar energy and
possession of biofuels. With the anaerobic, covered
Aquacell pond, a net energy production can be achieved.
Currently , the wastewater plant is the
largest nonwater department user of electricity, con-
suming 2.4 million kilowatt hours per year. Both of
the alternatives suggested by Brown and Caldwell,
ODl, and one we are not supposed to talk about, OD7,
would use five and three times the present rate,
respectively.
How about land use? According to Solar
Aquacell, only a small land area of one acre per ten
thousand people is needed for secondary treatment.
Gruen Gruen 6 Associates on Page 533 of the
Draft EIS/EIR says the total study area in 1999 will
have a population of around 277,000, in conflict with
what the person from Jones & Stokes said. That popu-
lation would require a land area for treatment of just
under 28 acres.
In the Solar Aquacell System, toxins, heavy
metals, pesticides, herbicides, pathogens, and carcino-
gens are metabolized by the hardy water hyacinths, and
detoxified and sterilized by ozone. Total dissolved
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salts can be reduced by ten to twenty percent by the
biomass uptake, while the natural precipitation and
evaporation losses are eliminated.
There is a short construction time -- About
six months on the average — and environmental bene-
fits greatly reduce project delays and costs. Actually
this kind of system is only one-half to one-quarter the
construction cost of conventional technology.
The reclaimed water from OD/RE5A and B has
an average cost of $745 per acre foot compared to
$200 per acre foot for the San Felipe Project mentioned
on Page 417 of the EIS/EIR. Using the cost from Solar
Aquasystems of 25 cents per thousand gallons of
reclaimed water, one acre-foot would cost only $81.67.
On the same page, the Draft says, "The high
cost of these two reclamation alternatives appear
extreme when compared to the nonreclamation options,
but the cost of developing alternative water supply
sources in.the future should also be considered."
We must not be satisfied with partial solu-
tions to the problems we are now faced with. Only a
systemic approach can provide satisfactory solutions t<
our situation. I do not consider myself an expert in
this field, but I do think the evidence I have pre-
sented deserves more attention than it has received.
2
I urge the EPA to recommend coverage of these innova-
tive systems before reaching a decision.
Thank you.
CHAIRMAN WALKER: Thank you, Mr. Paiss.
The next card that I have is Mr. Dave
Bockman.
MR. DAVE BOCKMAN: My name is --
This thing doesn't work.
My name is David Bockman. I'm
CHAIRMAN WALKER: Can you hear
Can you hear the witness in the back?
FROM THE FLOOR: Yes.
FROM THE FLOOR: I don't know.
MR. BOCKMAN: My name is David
a resident of the City of Santa Cruz.
I have a Bachelor of Science Degree in
Chemical Engineering from Purdue University, and a
Master of Science in Chemical Engineering from
Northwestern University. At one time I worked for
the government. I was concerned with the protection
of water quality from certain plants set out for pro-
ducing catalysts for the petroleum industry.
But I'm here not representing myself tonight
but for the Sierra Club, and specifically for the
Santa Cruz Regional Group of the Sierra Club, which
a resident --
in the back?
Bockman. I'm
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has approximately 1100 members in Santa Cruz County.
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compliance with requirements is December 1st, 1982.
First of all, I would like to -- I want to
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Obviously this cannot be met.
skip around a bit tonight because I would like to
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Indications are, I believe, that the EPA has
touch on a few things.
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stated, and also Mr. Jones, the Executive Director of
As you pointed out before the previous
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the Regional Water Quality Control Board, only a few
speaker, there are several speakers here that will
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days ago that the granting of the waiver or denial
talk essentially as a group, and we more or less
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would probably occur on the order of two years from
endorse each other's comments.
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now, not — not on April 1st, 1980.
First of all, it should be pointed out that
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Perhaps I should clarify.
the City of Santa Cruz is operating under a cease and
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In any case, the statement was made by the
desist order. No. 7901, adopted by the Regional Water
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state and by the EPA on various occasions that the
Quality -- the California Regional Water Quality
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city must go ahead with what they are proposing because
Control Board Central Coast Region in San Luis Obispo
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they have to do it or otherwise somebody's going to
on February 9th of 1979. This is an order requiring
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throw them in jail or something like that. I don't
the City of Santa Cruz and Santa Cruz county to cease
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think that's the case. And I think what — what the
and desist from discharging waters contrary to require-
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EPA should be doing here and it should be studying in
ments described by the California Water Quality Control
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this document is what should be -- what's best for
Board Central Coastal Region. Amongst other things,
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this region in terms of protecting water quality and
it sets out, under -- on Page 4 of that order a series
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improving water quality. And if this takes a little
of compliance dates.
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bit longer, so be it. I think that's what should be
Basically, they have two different cate-
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done .
gories. One, if the City of Santa Cruz receives a
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I would like to point out that -- that a
waiver from secondary treatment, and if the waiver is
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course be -- what's being enforced here is the Federal
denied. It indicates here that the date the waiver
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Water Pollution Control Act which, amongst other
would be granted or denied is April 1st, 1980. Full
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things, unless this was amended, also it says the new
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law sets this goal. "Water clean enough for swimming,
boating, protection of fish, shellfish and wildlife by
1983."
I am perhaps reading from an old document.
Maybe that's been changed, but I think the basic --
maybe the date has been changed, but I think the basic
goal remains the same. And whether or not what's
being studied in this EIR/EIS will meet that goal is
uhat is of concern to us tonight.
First, I would like to point out certain
errors of omission from this document.
First of all, at — there is — in the front
there is a series of locations where this document was
sent, and it was sent to various state agencies. It
was sent, for example, to the State Hater Resource
Control Board, Division of Hater Quality, Mr. Neil
Dunham. Within the State Hater Resources Control
Board there is an Office of Water Recycling, which was
established in 1977 by the Governor of this state. I
know that this document was not sent to the Office of
Hater Recycling.
On Page 446 of this document, it indicates
the various state agencies to which this document was
referred for in the preparation of the Draft EIS/EIR,
and it lists the California State Water Resources
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Control Board, various pooplc within that ^njoncy. Not
a single person with the Office of Water Recycling was
consulted in the preparation of this document.
Obviously, the State has an interest in reclaiming
water.
At this point I would like to place as
exhibits three documents prepared by the Office of
Water Recycling, California State Water Resources
Control Board. The first document is called "Why
Reclaim Water?"
The second document is called "The Green
Solution: Wastewater Reclamation for Landscape
Irrigation."
And the third document is "Industrial Water
Recycling."
I passed out the first document, "Why
Reclaim Water?", to members of the audience and members
of the press here that are here tonight. The last two
documents I didn't have sufficient copies, and I could
only pass them out to relatively few people in the
audience and the press and members of local govern-
ments that are here tonight.
I am going to comment on the second two
documents, but I would like to make comments on the
first document since the audience has the document
tonight.
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It's pointed out on -- on -- on Page 14 of
the document the one thing that, "In January ,1977,
the State Water Resources Control Board provided a
major stimulus to water reclamation by adopting the
'Policy and Action Plan for Water Reclamation in
California.'"
I don't believe this EIS/EIR that's before
you tonight addresses that plan and action -- that
Policy and Action Plan adopted by the State.
In October, 1977, Governor Brown established
the Office of Water Recycling. In creating this
office, the Governor set an initial goal of tripling
California's use of reclaimed water by the end of
1982.
I don't believe this document that's being
presented here tonight addresses the concerns of the
State of California.
It's pointed out on Page 5 that at present,
as of May, 1979, more than 200,000 acre feet of
reclaimed water from about 200 treatment plants is
being reused each year for beneficial purposes in
California. There is an existing groundwater over-
draft in California. It's stated by the year 2000,
even with normal rainfall, there will be a shortage in
the range of three to six million acre feet of water
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annually. 6.7. percent of wastewater currently in
California is reclaimed. Wastewater reclamation will:
a. Provide a cost-effective supplemental
water supply.
Utilize a valuable resource: treated waste-
water.
Provide water quality benefits.
Provide environmental benefits through con-
servation of primary resources and energy.
There are several examples given in here of
reclamation projects in California, which I will not
repeat. It's stated, "Reclamation of locally avail-
able wastewater may well be the best and most eco-
nomical way to protect certain groundwater basins from
overdraft and at the same time conserve the enormous
amount of energy required to import water over long
distances. "
It's being proposed now, and the County has
agreed to accept the San Felipe project in the south
county. This is being heavily subsidized, and the
subsidization will probably increase because of the
increased prices for energy.
"Reuse of reclaimed wastewater provides a
reliable and safe water supply for numerous bene-
ficial uses and frees existing water supplies for
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domestic and other priority uses,"
I think the document on Pages 10 et sequens ¦
Pages 10 through 13 discusses where we can use
reclaimed water: agricultural irrigation, landscape
irrigation, industrial reuse, groundwater recharge.
"Other beneficial uses - Reclaimed water can
be used for recreational purposes." Santee, in
California, in San Diego County, a large lake has
been developed for recreational use by the residents
there.
"Wetland refuges can be created or existing
marshes enhanced for the preservation of wildlife."
There are several other illustrations of
reclamation use in this document. The Whittier Narrows
Reclamation plant, referred to by Mr. Hills.
On the last page, the Frank Bonelli Regional
County Park, which provides nearly 1,000,000 gallons
of reclaimed water each day to irrigate a 2,000-acre
park.
It's obvious that — that the State is
interested in water reclamation. Next week on
September the 6th and 7th at California State Poly-
technic University at Pomona, the office of Water
Recycling, the California Department of Health Services ,
the California Department of Water Resources, the
California Association of Reclamation Entities of
Water# the American Water Works and the California
Water Pollution Control Association are sponsoring a
wastewater symposium entitled "Wastewater Reuse for
Groundwater Recharge." The question is here at this
point, given the fact that the State of California and
the EPA is interested in reclamation, how it can carry
about such a system in this case here. This is not
the Central Valley. This is not Orange County, etc.
So how do we go about doing this?
I think the previous speaker probably best
indicated the system that could be utilized in this
case. The system he described has been developed by
Solar Aquasystems, and other firms have been involved
in similar systems. And the plant is being constructs
in Hercules, California, at this time, and it is
expected to go into operation in 19 — in November of
this year.
So why — why is this not being discussed in
this Draft EIS/EIR? The statement is made, "Well, we
never heard of it until this week." On the other
hand, there was an article written in the "Los Angeles
Times" on April 21st, 1976, entitled "Hyacinths
Thrive on Sewage, Clean Polluted Water," reporting on
a paper presented by Mr. Bill Wolverton of the
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National Aeronautics and Space Administration, a
federal agency which is, I think, probably well known
to you, to EPA.
Anyway, a copy of this article was given to
Mr. Wilson Fieberling, the Director of the Department
of Public Works of the City of Santa Cruz, and I will
place this article from the "Los Angeles Times" as
another exhibit at this point.
CHAIRMAN WALKER: Thank you.
THE REPORTER: I need just a moment to changef
paper.
(Brief pause.)
CHAIRMAN WALKER: All right. Me are back on
the record.
I don't want to cut short your presentation,
sir, but I think you can assume that EPA is aware of
the problems of water recycling and reuse. We are,
however, limited by certain restrictions, both by
statute and regulation. And it was previously
explained, and I think has got to be considered when
we are talking about this particular project, that
there are cost limitations that have to be met. I
think we are aware of the fact that water recycling is
a very desirable thing to do, and we do encourage this
and fund it whenever we can. But there are some times
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when we simply cannot do it.
Now, if all of the people who are on this
list are all going to say the same thinq, I have to
assure you that we are aware of this, and we like to
hear about it, but we would also like to hear about the
alternatives that are proposed here tonight. There
are certain limitations as to how much water recycling
we can fund, and there are people who sue the agency if
we depart from those regulations.
MR. BOCKMAN: The Sierra Club realizes there
are these cost limitations, and I think it will be
demonstrated and it can be demonstrated that systems
such as Solar Aquasystems propose to construct is more
cost effective than any of the alternatives presented
to you tonight.
CHAIRMAN WALKER: We would like to hear about
that. We are aware of the desirability of recycling
water. If there is new information about the cost
effectiveness, we would certainly like to hear about
that.
MR. BOCKMAN: Well, as you know, beyond
this, I suppose I mentioned there is a symposium on
September 11th and 12th, a seminar on Aquacell Systems
on wastewater treatment, which is cosponsored by the
Environmental Protection Agency, the United states Army
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Corps of Engineers, the University of California
Extension, and the California State Hater Resources
Control Board. And that seminar on September 11th and
12th deals with systems such as the proposed, and it's
obvious from EPA's interest in this symposium that
it's, like you said, interested in the subject itself.
The fact that — that EPA issued an NPDES for the
City of Hercules for their plant, which I believe is
capable of actually 2,000,000 gallons per day, about
one-tenth the size of this unit that's proposed here,
is indication that it, EPA, is willing to consider
innovative proposals.
But these are not being considered in this
Draft EIS/EIR. Where is this information? And it has
to be considered here, and it was never considered by
the Board of Control or by the -- the consultants for
the Board of Control or by Jones t Stokes. There is
no evidence that any of this was ever considered at
any point in the discussions.
Several of the other speakers will discuss
the costs of this, so X won't go into that. I would
like just to quickly add some comments regarding, to
change the subject, the question of Nearys Lagoon.
We are very much concerned with potential
expansion into the wildlife area at Nearys Lagoon.
84
At this point I would like to place in the
record a letter written by Mr. Gary A. Patton, Super-
visor of the Third District, Santa Cruz, entitled
"Expansion to Permit Secondary Treatment at Nearys
Lagoon Sewer Plant." To that was appended a letter
dated January 11th, 1977, signed by Edward Y. Brown,
Executive Director of the California Coastal Commission
discussing potential impacts on the Nearys Lagoon site
from the proposed expansion.
X would also like to point out -- I would
also like to place in the record a memorandum from the
Director of Parks and Recreation of the City of Santa
Cruz to the City Manager of the City of Santa Cruz,
dated August 21st, 1979, entitled "Nearys Lagoon,
Phase II - Authorization to go to bid." This came
before the City of Santa Cruz City Council last
Tuesday night, and they approved the plans and specifi-
cations for Nearys Lagoon Park, Phase II, and authori-
zation for the City Manager to go to bid to buy for
park improvements the entire area proposed for
expansion at Nearys Lagoon.
It's obvious that the City has very great
interest in protection of the — the — the park area
at Nearys Lagoon and has no intention as the -- for
expanding into that area. If it did, we would have to
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wipe out the nxiiilimj pork in th.it .iron.
I would like to make one major correction in
the -- in the text. On Pages 253 and 254, there is a
section entitled "California Coastal Zone Conservation
Commission." As you know, or at least you should know,
the California Coastal Zone Conservation Commission
became extinct on January 1st, 1977, and it was
replaced by the California Coastal Commission, which
has followed from the passage of the California Coastal
Act in 1976. The discussion here in terms of con-
formance with Coastal Act policies is at this point
archaic, and there should be substantial discussion in
the Draft EIS/EIR about conformance of the proposed
project with Chapter 3 of the California Coastal Act
of 1976, which establishes certain policies for pro-
tection of the coastal zone in the State of California.
This document is completely deficient in that respect,
and I would ask that document -- document be sub-
stantially amended to -- to reflect the positions
taken by the State of California in passing the
California Coastal Act in 1976.
Thank you very much.
CHAIRMAN WALKER: Thank you, sir.
We are about to take a recess; but for the
sake of the record and to keep everything tidy here, I
86
will announce that we are marking I lie fiiuL document
entitled "Why Reclaim Water?" as Exhibit No. 9.
(Whereupon, Ilparinq Exhibit
No. 9, document rn I: i t lod
"Why Reclaim Water?", was
incorporated into the
reco rd.)
CHAIRMAN WALKER: The next one that was
titled "The Green Solution," will be marked as Exhibit
No. 10.
(Whereupon, Hearing Exhibit
No. 10, document entitled
"The Green Solution: Waste-
water Reclamation for Land-
scape Irrigation," was
incorporated into the
record.)
CHAIRMAN WALKER: And the one with the blue
cover that's entitled "Industrial Water Recycling" wil]
be marked Exhibit No. 11.
(Whereupon, Hearing Exhibit
No. 11, document entitled
"Industrial Water Recycling,
was incorporated into the
record.)
CHAIRMAN WALKER: The copy of a clip from
the "Los Angeles Times," Wednesday, April 21st, 1976,
will be marked Exhibit 12.
(Whereupon, Hearing Exhibit
No. 12, one-page newspaper
article entitled "Hyacinths
Thrive on Sewage, Clean
Polluted Water," Los Angele:
Times, April 21, 1976, was
incorporated into the
reco rd.)
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CHAIRMAN WALKER; The letter from the City
of Santa Clara to the 201 --
MR. VAN AT,I,F.N: County of Santa Cruz.
CHAIRMAN WALKER: City of Santa Cruz. Excuse
me .
MR. VAN ALLEN: County of Santa Cruz.
CHAIRMAN WALKER: County of Santa Cruz to
the 201 Board of Control -- That's the one that threw
me -- will be marked Exhibit 13.
(Whereupon, Hearing Exhibit
No. 13, two-page letter to
the 201 Board of Control
from Gary A. Patton, January
26, 1977, with four-page
attachment, was incorporatec
into the record.)
CHAIRMAN WALKER: The memorandum from the
City of Santa Cruz, on the letterhead — from the City
Manager of the City of Santa Cruz to the Director of
Parks — no, from the Director of Parks and Recreation
to the City Manager of the City of Santa Cruz, dated
August 21st, 1979, will be marked Exhibit 14.
(Whereupon, Hearing Exhibit
No. 14, one-page memorandum
to City Manager from Direc-
tor of Parks and Recreation
August 21, 1979, was incor-
porated into the record.)
CHAIRMAN WALKER: Mr. Paiss, I noticed that
you were reading a document. I think it would be
88
helpful if you could furnish the Reporter with a copy
of that; and if you do, I will mark that as Exhibit
IS.
(Whereupon, Hearing Exhibit
No. 15, four-paye statement
of William Paiss, August 29
1979, with three-page
attachment, was incorporate!
into the record.)
CHAIRMAN WALKER: Now, as promised, we are
going to take a recess. I will admonish you that we
have about 16 or 17 more cards here, so we can't take
too long a recess and still get through the night.
Those of us who came from a long distance plan to stay
for the whole night anyway, so we are here for the
night. It's up to you how long you want to go.
There are a couple of things that I would
say -- And you can talk to the staff people, the
resource people during the recess and perhaps satisfy
yourselves on this subject -- on the matter of water
recycling. We are aware of the problems of water
recycling. We are also under some constraints. So
this may affect some of the arguments and statements
you want to make to us. We know about the problem, anc
we know about the desirability of it, so perhaps you
can help us solve our constraints.
So now we will take a recess for 15 minutes,
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or until ten minutes to 10:00.
(A recess vas taken from 9:33 p.m. to 9:50
p.m.)
CHAIRMAN WALKER; We will go back on the
record now and continue this public hearing.
The next card that I have is Mr. Gordon
Ca11, Cupertino.
FROM THE FLOOR: He hasn't come back from
the recess yet.
CHAIRMAN WALKER: Well, let's wait a minute.
There may be people outside who didn't hear the gavel.
It wasn't a very loud one.
Mr. Gordon Call? The second time of asking.
FROM THE FLOOR: He's not here right now.
CHAIRMAN WALKER: Do you know for sure he's
not here?
FROM THE FLOOR: He's coming.
CHAIRMAN WALKER: He's coming.
FROM THE FLOOR: He's coming back. He had
to take his mother home.
CHAIRMAN WALKER: We will put his card aside
and call the next one. Mr. Wallace M. Dale?
MR. WALLACE M. DALE: Mr. Walker, members of
the Hearing Board: my name is Wallace M. Dale. I'm
with the Lipton Company on Delaware Avenue, and I come
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here tonight as a member of tho Chamber of Commerce,
and I speak for the Chamber of Commerce.
I'm actually going to be addressing myself
to all three of your innings: first, second and
possibly a third.
We have a committee in the Chamber of
Commerce representing the major industries in the area
namely Pacific Coast Producers; John Inglis Frozen
Foods -- You heard them earlier -- Salz Leathers,
who you also heard from earlier tonight, which is a
tannery? and Lipton, which also is a food producer
here in Santa Cru2.
The cost of the alternatives, I will address
two of them which show -- in the smaller booklet on
Page 17 show a total on the ODlA, which is secondary
treatment, showed total costs, annual costs, for the
four industries just mentioned of $555,000. That's
based on 1976 costs.
The advanced primary, OD7, which is the
third inning, is a total cost of $160,000 per year
for the four industries combined, $400,000 lesser fee.
I would like to address the employment
picture here in Santa Cruz.
These four industries represent 1200 jobs
here in the Santa Cruz area, who mostly are Santa Cru?
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r ''-i i tli'iils . The uiiCMiipl oyinon t into here in r..niln Cruz
currontly runs about two points higher, or about 25
P*' rcrnt higher than the entire state. We have almost
a depressed -- I won't say "depressed." We do have a
higher unemployment rate in Santa Cruz than we do
normally in the state.
You heard from two people tonight possibly
about moving their operations to new locations because
of the higher costs of secondary treatment. I know
>nother one who will speak shortly who will address
the same thing.
An additional $400,000 of inflationary rate,
which will drive it up by 60 to 100 percent, will
drive many manufacturers out of town. We can't afford
this from our industrial base here in Santa Cruz. We
can 't afford the loss of the jobs here in Santa Cruz
that will result with these alternatives. They will
forced into another one of their plants in the
California area, namely out of the Santa Cruz area.
With the unemployment rate as high as it is
in the Santa Cruz area and the potential loss of jobs
as a result of secondary treatment, we of the Santa
Cruz Chamber of Commerce urge that every consideration
be given to the advanced primary concept which would
be addressing itself to the waiver and the approval of
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the waiver iippl i t-n t i on .
Thank you.
CHAIRMAN WALKER: Thank you, Mr. Dale.
Mr. Call? Is he here? You are Mr. Hall or
Call?
MR. IIALL: Robert llall.
CHAIRMAN WALKER: Let's first find out. We
had a Mr. Call.
FROM THE FLOOR: He's not back yet. I will
keep an eye out.
CHAIRMAN WALKER: All right. We will hold
his card.
And, excuse me, sir. The next card -- I
did promise to take them in order. That would be Mr.
William Doyle.
MR. WILLIAM DOYLE: Yes. Mr. William Doyle.
I'm a resident of the City of Santa Cruz and pro-
fessor of biology at the University of California
Santa Cruz and also Director of the Marine Program at
UCSC.
And I'd like to address comments to two
issues, both of which concern the marine environment
and perhaps our marine laboratory, which is situated
on the open coast.
The first comments will be focused on the
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alignment of the long ocean outfall, something which I
think wasn't covered too well in the combined KIR and
li IS. Almost all of the comments which have been made,
regardless of the type of treatment or regardless of
whether it's recycling or deep ocean outfall, do
require some back-up, which is a long ocean outfall,
so in case of failures of recycling on land, you have
a place to dump it. You can't store it for long
periods of time.
The concern with a long ocean outfall, as fa
as I'm concerned, is that the recommendation in both
the combined EIR and EIS is for the 1C alignment,
and I think the position of the outfall is probably of
greater importance to many people than is the type of
treatment because of the specific location of Santa
Cruz and the specific location of the -- of an ocean
outfall.
The concern that I have is one of meeting
ocean standards and all of the requirements, but still
not always understanding all of the toxic compounds or
potentially toxic compounds which may come out in the
effluent over time. If we focus on what we know, we
don't always know some of the compounds, and EPA, I
think, is increasingly concerned with organic and othe
types of compounds which may be present in effluents
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in very small concentrations, but which may bo toxic.
The concern here is some royards, as far as I'm con-
corned as Director of the Marino Pro
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or either the OD7 doesn't meet the standards; the con-
cern that there is a still farther out alignment which
has been looked at and in the very nice modeling that
was done in trying to determine vector hits in the
worse possible situation. There was a real attempt by
the consultants to look at this problem of the location
of the sewec outfall and the potential impact on an
intake system and, therefore, on experiments at the
Marine Lab. The comparison of the potential vector
hits from the worst possible situation between the
1C alignment versus the ID alignment, there is a
difference. Even though the percent of hits would be
very small with a 1C alignment, nonetheless there is a
possibility that a material or compounds could be
picked up in the intake system and small concentration
of some unknown compound could have an effect; whereas
the ID alignment, the frequency of hits and the
dilution is even greater, so there is just an extra
margin of safety.
The proper time to be concerned about this
is now because once that intake — once the outfall
system is in place, once that diffuser system is put
down, it would be terribly expensive to go back and
try to correct a system which, in fact, was shown
perhaps to have some sort of an effect upon the
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activities at the Marine Lab. So it should be seri-
ously considered, whether the extra margin of safety
is, in fact, worth the expense.
And, again, the time to do it is now. You
are not going to go back and spend millions of dollars
to get the divers and other people out there to move
the terminus out to the 120-foot depth rather than a
hundred foot depth.
The second issue I would like to address is,
in part, in the EIS/E1R, but also part of the OD7, and
that has to do with the type of sewage treatment,
primary versus secondary. And I am going to restrict
again my remarks just to the assumption that perhaps
one of these two types of treatment -- treatments will
be possible and that, in fact, it will be a long ocean
outfall.
One of the concerns and reasons that secon-
dary treatment has been gone to is to attempt to clean
up the effluent, to remove most of the organic matter.
As a result, one gets an effluent which has, through
biological action, that is phytoplankton, primarily
most of the organic, the large organic molecules out
of it, so one gets a fairly clean effluent with lots
of nitrates and phosphates and other residuals in the
effluent, whereas primary treatment, the larger
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*J 7
/«. i' f i I ' i <'i»in/c(| f 11 .< < , <1 lot of < w «(.t it i < * m.i M e r i »
icmoved, )>ul. a very i mpor tan i di f forcnco, I think, for
in.it i ni» cnv i rniiiin-n t r. i thai much of the phosphates and
nil,j.iletf, as during the? primary IrfnhinMit, is si ill
combined with tip- urqanics as part of I he proteins,
yoni u»-i|.inir, nt.tl I n' that ijoes out with I J if el 11 uen I .
Now, why is that important? When someone
<1 i seha i
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the -- whether secondary treatment is always necessary
in marine -- in the marine environment, except when you
hjvi! an estuarino or a bay or some other local condi-
tions which might interfere with diffusion and uptake
and so on.
So, to summarize, I think my comments -- I
would prefer -- I would like to see more attention
given to an evaluation of the 1C outfall versus the
ID outfall. And I think the extra margin of safety
when you are investing this much in an outfall, the
extra amount of money might be worth being spent at
this time, although it's a very local concern; it's
just research at a marine station.
Now, the other concern is, then, just the
primary versus secondary treatment, and I have seen no
persuasive argument for the need for secondary treat-
ment where this particular outfall terminus is to be
put. And I say that in spite of the fact that the
person — the people who are going to get hit hardest
if there is a problem are going to be the people at
the Marine Lab because you are taking it up into our
intake system.
CHAIRMAN WALKER: Thank you. Dr. Doyle.
Mr. Call?
MR. CALL: I didn't plan to be a speaker. I
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was asked to sign it as an attendance card --
CHAIRMAN WALKER: Oh, all right.
MR. CALL: — by your ck-ik .
CHAIRMAN WALKER: Thon we will call on the
next one.
I would like to say something nice about this
audience right about this time. We have had some
pretty heavy speeches here, and I haven't seen anybody
go to sleep or walk out or anything, and the attendance
has not diminished. I really am quite astonished.
That was a personal remark.
FROM THE FLOOR: Thank you.
CHAIRMAN WALKER: Now, I will call on Mr.
Ralph Kenworthy.
MR. RALPH KENWORTHY: Mr. Walker and members
of the panel: my name is Ralph Kenworthy. I live in
Modesto, California. I am vice President/Operations
Manager of the John Inglis Frozen Foods Company, who
operate a freezing plant here in Santa Cruz.
The John Inglis Frozen Foods Company has
been a major industrial sewer user in Santa Cruz for
the past 24 years and has always tried to deliver the
best possible effluent under the prevailing circum-
stances. We feel we will be seriously impacted by the
Wastewater Facilities Plan being considered and desire
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Lo express our strong feelings about the alternatives.
We employ a crew of 350 people for about
six months of the year and have about 25 full-time
employees here in Santa Cruz. We freeze spinach and
Brussels sprouts for the retail and food-service sectors
of the national market and, in fact, produce over one-
third of all the frozen Brussels sprouts consumed in
this nation.
The continued efficient operation of this
manufacturing plant is of vital concern to our
employees, to the growers of the area who supply our
products, and to the corporation owning it.
We have invested about $150,000 in machinery
and equipment to enhance the conservation of water
used in the processing and in means to reduce the
pollution of the effluent. We are now at all times
delivering industrial wastewater that meets the
California State Water Resources Control Board Ocean
Plan, with the possible exception that our suspended
solids levels are about 150 milligrams per liter as
compared to the 50 to 75 milligrams required by this
plan. We are willing to add the 40 mesh hydro-sieves
which would be required and which would cost about
$20,000 to our own in-plant systems, and then we would
be able to totally meet the Ocean Plan.
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The BOD levels average nbout 15 0 milligrams;
per liter, which is as good as or better than the
average domestic effluent. There are no known toxi-
cants in our wastewater.
With this background, I would like to point
out our concerns and our evaluations of the alterna-
tives being considered for the municipal Santa Cruz
wastewater treatment.
We paid $21,123 for sower services in 1978.
As of July of this year, our rate has been increased
by two-thirds, with another substantial increase
scheduled for 1980.
The most favorable alternative from a cost
standpoint, OD7, is projected to raise our annual
costs to about $45,000. The full secondary treatment
plan, ODlA, is projected to raise our costs to $145 ,00(
per year.
And I would note that these are 1976 dollars,
and I suspect there are substantial inflationary
aspects to these indicated projections.
Since we pack 30,000,000 pounds of frozen
vegetables a year, this would make this portion of
our costs attributed to sewage disposal about one-half
cent per pound of finished product. It is normal for
distribution and retail selling costs to bring the
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price to the consumer oi" any product to ;ibout twice t ho
maiuif aetur Ing cost or, in other words, it would cost
l lir* rin.il con r .ihunt one cent per pound for the
product of our plant attributed to sewage if 0D1A is
selected.
We leel that such sewage costs would place
us in such a poor competitive position compared to
frozen vegetables packed in other areas that we would
have to seek' means to lower it at this plant by capi-
tal improvements and by in-plant technology, or we
would have to move the operation to another city.
John Inglis Frozen Foods Company has freezinc
plants in four other California locations, as well as
two in the State of Washington. Santa Cruz is now by
far the highest cost plant as compared to Modesto,
Watsonville, Salinas or Santa Maria in terms of sewage
rates.
Should we be successful in materially reduc-
ing our effluent volume, or should we have to termi-
nate operations here, it would have a significant
impact on the revenue plan for OD1A, as the removal of
$135,000 of annual receipts would pass a burden upon
the remaining users.
The study of the consultants retained by the
City and the testimony of most authorities on the
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subji'cL indicates that I lie prim.ny cliemii-al 1 i ,>.i I men L
plan, 0D7 , would adoqiiii t p 1 y |irol i't'1 t ho environment in
I he ocean and I hr intrrosts of the local eilizenry.
Since 0D7 is the least costly and the most efficient
fro.ti the standpoint of energy consumption, we urge that
it be selected and that a waiver of sccoiulii ty treatment
under PL 95-217, the Clean Water Act of 1977, be
granted.
Thank you.
CHAIRMAN WALKER: Thank you, sir.
Do you have a copy of your remarks which you
could hand in?
MR. KEHWORTHY: Yes.
CHAIRMAN WALKER: It will be marked Exhibit
16.
(Whereupon, Hearing Exhibit
No. 16, three-page statement
of Ralph Kenworthy, was
incorporated into the
record.)
CHAIRMAN WALKER: Deena HurwitZ?
MS. DEENA HURWITZ: Thank you. Good
evening.
My name is Deena Hurwitz, and I'm on the
staff of the Resource Center for Nonviolence. I'm
representing a group called People For A Nuclear
Free Future. In the best interests of this group, an»
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taking into consideration one of the most imminent
issues of our time, I'd like to address the dilemma of
waste management in relation to energy options.
When considering new methods of treatment or
exemptions from standard laws set up to ensure protec-
tion against pollution and wastefullness, we must keep
in mind several things. What is most economical,
efficient and ecological. Is the present waste treat-
ment system in Santa Cruz as economical as it can be?
This year the total operating budget for the Nearys
Lagoon Treatment Plant was $1,225,000.
What of efficiency? The Nearys Lagoon
Plant is Santa Cruz's largest individual energy con-
sumer at two and one-quarter million kilowatt hours
per year. Compare that to the 500 kilowatt hours per
month which is a high PG&E estimate for an average
household.
As for ecology, the more water we direct and
drain without adequate replenishment and reclamation,
the less water we will have available, especially with
a propensity for drought.
And we should also look at the chemical
nature of waste outfall off our coast. Even with
comprehensive waste treatment, the question must still
be raised as to the harm of the treatment chemicals as
106
they build up in years of effluent discharge. without
secondary treatment, a greater concentration of
chemicals would be required to meet treatment regula-
tions.
What is the savings in cost compared with thc-
added chemical intensity?
Even with these questions satisfied, we
always need to be looking for better solutions. Cost
estimates, population and energy use are increasing
exponentially. Will it still be efficient, economical
and ecological in 20 years to treat our sewage as we
do now and keep looking for new water sources and
areas for landfill? We have to begin now to plan for
the future.
Let me explain in a line my point.
Sim Van Der Ryn, former California State
Architect, said, "Waste is a resource to be managed,
not a problem to be disposed of." The modern waste
management system manages to dispose of useful
resources while creating a demand for those very same
substances.
Consider the wealth of natural fertilizer
being chemically poisoned and then dumped into our
oceans and rivers. Algae consume the still-present
nutrients, causing rapid overreproduction as they
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u:;'' up all the available oxygen. The result of such a
depletion is the death of all aquatic life that may
have survived the chemical residues.
Meanwhile, agribusiness has a lucrative
commerce in the production of artificial -- petroleum
fertilizers. At a time when petroleum is becoming
scarce, we should be doing all we can to use alterna-
tives th^t are renewable, cheap, safe and clean.
Let's take a quick look at energy use.
Transportation fuels alone now comprise over
25 percent of our total national energy demand, while
some 28 percent of our energy consumption goes into
low-temperature tasks, such as space heating, cooking,
air-conditioning, etc. The main energy consumer is
industry, at 41 percent. The figures are slightly
different for Santa Cruz County, but the point is
the same: energy demands are great and increasing
every day.
Energy is also lost in generation, trans-
mission and at end use. According to Amory Lovins,
increased electrical expansion to the 150 quad-
rillion BTU's by the year 2000 would result in energy
waste approximating the nation's total energy con-
sumption in 1971.
So the picture sums up to a problem in terms
i oe
of energy deinnnc] nnd consumption, water supply, land
use and, of course, pollution. The pertinent question
here is what can be done in terms of waste treatment
to help alleviate these pressures?
Well, a number of thinys can be clone. And a
number of things have already been done.
Under the general heading of biomass con-
version come anaerobic digestion, pyrolysis, incinera-
tion and fermentation.
Biomass conversion means converting plants
and organic wastes directly to organic fuels and
fertilizers. Efficiencies range from 75 to 98 percent
for pyrolysis, which is the heating of organic wastes
in the absence of air at atmospheric pressure to pro-
duce combustible gas, char and oil, to about 37 percent
for anaerobic digestion. The general process yields
methane gas, compost and fertilizer methanol, an
octane-rich alcohol and char oil.
Accounting for conversion losses, American
waste streams could still produce nearly five quad-
rillion BTU's of methane and char oil, which is about
seven percent of the current US energy demand, accord-
ing to Dennis Hayes, Director of the Department of
Energy Solar Energy Research Institute.
The National Aeronautics and Space
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Administration estimate that, by the year 2020, 30
percent of the nation's gaseous fuel, or 13 trillion
cubic feet, and ten percent of our liquid fuel require
ments can be met by bioconversion techniques applied
to industrial agriculture and organic waste sources.
In 1972, the Environmental Protection Agency
commissioned the International Research and Technology
Corporation, IR&T, to do a feasibility study of solid
waste conversion into food and combustible fuels.
I
Focusing on urban wastes, the study summarized the
sources of organic solid wastes and concluded that the
roost economical technique both to help convert large
quantities of waste to energy and to reduce the waste
burden was pyrolysis of mixed municipal wastes for
fuel, which could then be burned as a supplemental
fuel in conventional power plants and industrial
furnaces.
They concluded, furthermore, that this
should command the bulk of the agency's research funds
A highly successful program utilizing this energy and
resource recycling for urban waste is currently
operating in St. Louis, Missouri.
The EPA is also subsidizing S3 million out
of $4 million for an urban waste recycling system
designed by Garrett Research and Development Company
110
for two small communities in Southern California,
Escondido and San Marcos. For each of the 200 tons of
waste produced daily, one barrel of oil, a small
quantity of fuel gas and recycled metals and glass are
generated. Garrett officials estimate that the plant'
operating costs of $8 per ton will be 20 percent lower
than the costs of disposing urban waste in conven-
tional systems.
Although the quality of natural gas, at
1,000 BTU ' s per cubic feet, is still greater than
biogas, 600 BTU*s per cubic foot, the supernatant, or
sludge, as an additional byproduct enhances the over-
all value of energy production through bioconversion.
Plus the fertilizer is superior because it is highly
concentrated as opposed to a much more diluted super-
natant from conventional treatment. This is an
obvious asset to a highly agricultural county such as
Santa Cruz.
Another attractive waste management option
is the aqua- and polyculture integrated biosystem.
This combines black and gray water treatment and
settlement with water purification, plant and animal
production for food, and methane digestion for com-
bustible gas. After wastes are settled and collected,
the remaining suspended solids undergo detoxification
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through biological filtration, with the aid of
detritivores and bacteria to break down nitrites and
nitrates. These are utilized by aquatic plants, which
in turn, produce oxygen and carbohydrates for other
animals in the ponds. The plants can either be used
for feed or chopped or anaerobically digested to pro-
duce methane gas.
Although still a pioneering field, aqua-
culture as wastewater treatment has inspired promi-
nent research from NASA to Solar Aquasystems,
Incorporated, which we heard some about. This firm is
currently building a system for the City of Hercules,
California.
In fact, the 1977 Clean Water Act requires
that agricultural and aquacultural alternatives for
wastewater reuse be evaluated and encouraged as treat-
ment mechanisms.
Tertiary treatment effluent is produced at
vastly reduced energy and cost, and can be used for
irrigation or industrial reuse. With a further pro-
cess of ozonation or chlorination, the water can be
reclaimed for drinking.
Problems with toxic industrial materials,
such as plastics, paper and chemicals, can be met with
proper settlement at moderate cost> and attention to
112
1 carbon/nitrogen ratio, the two main decomposing ele-
2 ments.
3 Obviously this is but n simplified ovaluatioi
4 of wastewater treatment options. An increased emphasis
5 on on-site wastewater management, a district-oriented
5 decentralized system, should be considered as well.
7 This option was adopted in 1973 for Santa Cruz rural
8 districts.
g I would like to reiterate the imperative of
2Q our present energy dilemma and point out the wealth of
U potential available in proper reclamation of waste-
12 water. Before this city or any part of this county is
13 granted a waiver for secondary treatment or any pro-
H jects are adopted, serious research should be done to
15 assess alternatives in terms of energy need, cost,
lg efficiency and environmental impact. And special
attention must be given to energy demand in any pro-
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ject considered.
Thank you.
CHAIRMAN WALKER: Thank you.
Would you mind handing in a copy of your
statement for our record, which will be given Exhibit
No. 17.
24 (Whereupon, Hearing Exhibit
No. 17, five-page document,
25 Statement of Deena Hurwitz,
was incorporated into the
record.)
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K)
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1 CHA1KMAN WALKER: The next card is J.uon
2 E. Kllis.
3 MR. I.EON E. ELLIS: Good evening. X caught
4 somebody back there asleep awhile ago. I just thought
5 I would let you know.
6 CHAIRMAN WALKER: Well, don't tell the
7 Chairman.
8 MR. ELLIS: Two things that struck ray
g attention tonight listening to the speakers. One was
10 brinkmanship --
lj I'm Leon Ellis from Teamster's Local 912.
12 I'm sorry.
13 Brinkmanship, and the other was the site of
14 the Walti Schilling plant. The Walti Schilling
15 plant is no longer in existence because we, as unions,
jg and regulations did push them over the brink.
j7 He are very concerned about the 500 people
lg we represent in the plants, John Inglis and Pacific
19 Coast Producers. We are also very concerned about
20 their families and the people in the related Industrie
21 Our stand is let's get in compliance with the law if
22 we have to, get it done as soon as possible and get
23 on with the business of taking care of business.
24 That's all.
25 CHAIRMAN WALKER* Thank you, Mr. Ellis.
] 14
Ml!. Jack ColJit't?
MR. JACK COLLIER: Good evening. My name is
Jack Collier. I reside at 711 - 38th Street, Santa
Cruz.
My background includes 20 years as an engi-
neer, seven years of which was spent in cost-reduction
efforts. For the past two years, I have been on site
at the San Jose/Santa Clara Water Pollution Control
plant with a National Science Foundation grant studyin<
the use of earthworms to convert sewage sludge into
a fertile soil.
In your EIR, it's recommended on Page 290
that sludge be disposed of by landfill. I would like
to point out that our landfill areas are limited. At
a recent Civil Engineering Environmental Conference in
San Francisco, it was pointed out the landfills in the
Bay Area would last about approximately another 20
years. I think the City of San Francisco currently
trucks their garbage to the City of Mountain View,
and when that's filled, there could be such places as
Livermore or Santa Cruz.
Sludge is an organic material and should be
considered a resource, not a waste.
Conversion to a nutrient-rich soil, once
composted. Vermicomposting or composting by use of
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I-.i ft liwoi ms is «i iiromising ocoiioiuic moLhod of compos L i n > | <• u .iiul virus, if <'
problem, are controllable t.hrouqh r>olar-type steriliza-
tion.
In summary, I am s u
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also that we are treating it in a sustainable way that
it can go for not just 20 years, but for the future
hundred years, thousand years. Earth is an old planet,
butit won't be old if we destroy it today or 20 years
from now.
So I'm concerned that the secondary treat-
ment be permitted and enforced.
In my travels as a researcher across the
country, visiting different sludge treatment facili-
ties, I find that there is an initial concern by
citizens and other people about the treatment of
sludge, but there is also an irresponsible abuse, such
as the barging of Philadelphia sludges to Maryland
waters, SO that at a point when Maryland was going to
bring them to court, Philadelphia decided to do some-
thing else with their sludge and came up with a
Beltsville composting system.
Anyway, this kind of attitude that, if
sludge is out of sight or wastewater is out of sight,
that it's not being harmful to the environment, the
marine life, I'm concerned about that. And also I'm
concerned about how the $10 million will be raised,
what kind of cost increases that will have for the
citizens as well as the large users, like Salz Tannery
and John Inglis. In San Jose, the citizens are
118
concerned at a $3 million O&M cost, and this town is
considering, a much smaller town is considering a
$10 million increase.
That will be it. Thank you.
CHAIRMAN WALKER: Thank you.
MS. LIVINGSTONE: Oh, one more thing.
CHAIRMAN WALKER: Yes, ma'am.
MS. LIVINGSTONE: I want to make you familial
with this book put out with -- put out by the Office of
Appropriate Technology, 1979. It's the "Present Value
of constructing a sustainable future," and in it, it
has a couple of systems for treatment of wastewater
and one for treatment of sludge, which is our product.
CHAIRMAN WALKER: Thank you very much. We
will mark that as Exhibit 19.
(Whereupon, Hearing Exhibit
No. 19, document entitled
Present Value, Constructing
a Sustainable Future," was
incorporated into the
record.)
CHAIRMAN WALKER: The next card is Jane
Weed.
MS. JANE WEED: Good evening. I'm Jane Weed.
I live at 509 Seaside Street, and I'm with a group
called Energy Action of Santa Cruz. We are a private
nonprofit research organization that has been funded b;
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tjr.int from the California SI alp Knerijy Commission.
1
the last five years, China has built thifo million
We arc assessing the Santa Cruz County resource
2
biogas plants, using human and animal waste for fuel
potentials and energy use profiles. We are also
3
production. Using a resource readily available, they
developing plans whereby local government, business.
4
are minimizing their dependence on scarce, expensive.
industry and labor can implement programs for county
5
nonrenewable fuels. For every pound of organic waste
c-noryy self-sufficiency.
6
that goes into the Go-Bar plants, they yet one cubic
This brings me here tonight to make some
7
foot of biogas and natural gas, and the remaining
comments about the Environmental Impact Report.
8
residues they can use for fertilizers.
Santa Cruz government officials, large
9
Here, again, with use of fertilizers, they
engineering and consulting firms and many local citi-
10
alleviate the need to go to costly or environmentally
zens view sewage and wastewater treatment as something
11
dangerous chemical fertilizers which are predominantly
to deal with to inject with chemicals and pump it away
12
produced from petroleum.
and, in this case, dump it in the ocean. Out of sight.
13
In Lamar, Colorado, the municipal government
out of mind, except for the ever increasing costs of
14
is now engaging in the construction of a waste recla-
energy, chemicals and further sophisticated technolo-
15
mation plant that would recover methane gas and
gies to isolate us from our secretions. Historically,
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nutrients from municipal, agricultural and animal
sewage and wastewater have been valuable resources for
17
wastes. According to the Director of Public Works,
societies. And especially today, when the cost of
18
Mr. Bill Carnahan, it has turned a traditionally
nonrenewable fuels are rising so tremendously, we must
19
money-losing operation, such as sewage treatment, into
plan now for the future and for efficient, economic
20
an environmentally sound, cost-effective venture that
utilization of our resources. Sewage must be seen as
21
is benefitting the entire community.
a resource to utilize, not a problem to deal with.
22
Now, here in Santa Cruz, if we are to follow
Let's set the stage. Here are some examples.
23
the models of Lamar, Colorado, and the Co-Bar gas
In Asian countries, sewage has been used for
24
facilities of China, and given the existing figures foi
fertilizers and methane generation for centuries. In
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Santa Cruz, we could utilize the approximate 80 tons oi
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organic influents that will ultimately go into the
Santa Cruz system on a daily basis, and through
anaerobic digestion annually recover 150,000 cubic feel
of biogas or methane, more than enough to supply the
energy needs of the current' facility, not to mention
the recovery potential for fertilizer, which the
county could, in turn, sell to local farmers or use
as a revenue-producing export product.
Our estimates of the Energy Action Project
figures that the fertilizers could have a nutrient
content ratio of around seven percent nitrogen, 14
percent phosphorous and 12 percent potassium. This is
a pretty rich mixture, as it goes.
Given the cost of -- And this is some of
the things I'm about to talk about here come from a
letter from Brown and Caldwell. It's a table, F-l,
the estimated costs, and it details energy costs for
the future. It's Table 10-4, annual operation and
maintenance costs. And given the costs of energy for
the operation of an advanced primary treatment system,
and Brown and Caldwell's prediction is that the cost
of energy will increase tenfold to around 1.5 million
per year by 1997, thus outpacing the current inflation
rate by quite a large amount.
Santa Cruz can ill afford to overlook the
122
cost-effective potentials of the jiu.'Lhanc ami nutrient,
recovery systems instead of leaping into a technologi-
cal fix.
The alternatives detailed in the KIR by Brown
and Caldwell may promise ratepayers both questionably
adequate treatment facilities to pay for, but also the
increasing prices just to maintain and operate them.
This is economically unprudent to jump into this kind
Of thing.
It is our conclusion that the benefit cost
analysis of the Brown and Caldwell study did not thor-
oughly explore or compare the various sewage treatment
options as they did not consider the possibility of an
economically self-sustaining treatment operation, a
hybrid of alternatives.
Historically, water shortages in Santa Cruz
County have posed very serious dilemmas to agriculture,
industry and homeowners. At the current time, the ovei
draft of water in the Pajaro Valley is so severe that
farmers are now experiencing dangerous levels of salt-
water intrusion into the valuable fresh water aquifers
so needed in that region for irrigation, and has
resulted in the Planning Commission to commit to spend
anywhere from $25-50 million to construct the Zayante
Dam to impound water. Given that the waste treatment
facility in Santa Cruz will expel between ten to 13
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million gallons per day, it seems imprudent to spend
such exhorbitant sums on additional water resources,
while there is such a vast possibility for wastewater
reclamation. As has been detailed before, not only is
it possible to utilize this otherwise wasted resource
for agricultural and parkland irrigation, groundwater
recharge and industrial processes, we can also avoid
the economic drain and environmental devastation caused
by such proposed dams and reservoir projects such as
Zayante Dam.
Once again we question whether the consulting
firms looked carefully at the Zayante Dam and whether
they — they considered the water resource potential
available for the current and proposed treatment sys-
tem as a means to offset the water supply deficit of
the Santa Cruz bioregion. Though it is not common
practice for engineering and consulting firms to view
sewage treatment within the confines of a closed
ecological and economic cycle, we are of a mind that
any study must utilize a holistic approach in order to
obtain accurate and relevant conclusions. From our
analysis, the consultant's study failed to consider
these parameters; thus we have determined that it is
incomplete and ultimately unacceptable.
Energy Action of Santa Cruz is willint to offc
124
its services to both the EPA and Santa Cruz to
develop — to develop a sewage treatment plant which
will truly meet the needs of the community, industry,
business, labor and residents.
Thank you very much.
I would like to submit my comments if 1
could later.
CHAIRMAN WALKER: Later?
MS. WEED: Yes. May I send them to you?
CHAIRMAN WALKER: Yes. As I previously
announced, we will keep the record open for two weeks.
If you want to send it in, that will be very welcome.
Do you know where to send it? Environmental Protec-
tion Agency, 215 Fremont Street, San Francisco 94105.
MS. WEED: Thank you very much.
CHAIRMAN WALKER: The next card I have is
Jan Karwin.
MS. JAN KARWIN: My name is Jan Karwin. I*i
representing the League of Women Voters of Santa Cruz
County. I'm a resident of Santa Cruz City.
We appreciate -- This is going to be a very
short statement.
We appreciate having this opportunity to
comment on the Environmental Impact Report of the
Santa Cruz Wastewater Treatment Facility from the
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JK* r r.poc t i ve of the League of Wonion Voters.
Our League supports the management And
development of water resources in ways that arc bene-
ficial to the environment, with emphasis on conserva-
tion and high standards of water quality. As part of
the recommended conservation effort, we favor the use
of properly treated reclaimed water for agricultural
and landscape irrigation when benefits exceed the
environmental and economic costs.
We would like to express some areas of con-
cern in regard to the EIR, briefly.
First, the report does not provide sufficien
information to predict the long-term effects on marine
life in the vicinity of the wastewater discharge.
Apparently it is difficult to assess the cumulative
impact of the effluent.
Second, we are concerned that the cost com-
parisons of the reclamation alternatives do not take
into consideration the costs of developing a new
water resource. The need for this additional analysis
was recognized in the EIR on Page 417 where it is
observed that, although the costs of reclamation
alternatives appear high when compared to the non-
reclamation alternatives, the costs of developing
alternative water supply sources in the future should
120
be considered, since these water supply options* will
also have considerable economic and environmental
cost s.
While federal and state grants will fund
87 and a half percent of the capital costs of an
adequate treatment facility, it is our understanding
that an additional ten percent of the costs could be
covered if the facility were of an innovative nature,
such as reclamation processes that produce renewable
energy re source s.
Taking into consideration the operation and
maintenance costs, would it be more economical for
local residents to fund two and a half percent of the
capital costs of an innovative reclamation project
after receipt of federal and state grants, or would it
be more cost-effective to construct a comparable new
water resource?
We believe that it is important that citizen
understand the total picture of wastewater options and
complete cost analyses in order to make educated
decisions when bond measures are submitted for their
approva1.
Thank you.
CHAIRMAN WALKER: Thank you. Miss Karwin.
Let's see. The next exhibit number is No.
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1 20.
2 (Whereupon, Hearing Exhibit
No. 20, one-page document,
3 Statement of T.t.-ayue of Women
Voters of Santa Cruz County,
4 was incorporated into the
record.)
5
6 CHAIRMAN WALKER: Ronald Pomerantz?
7 MR. RONALD POMERANTZ: Correct.
8 It is extremely late, and many of ray points
9 have been covered. I'll try not to be too repetitive.
10 I graduated with a degree in economics from
11 the University here. Since ten years ago, I have been
12 a resident. I worked for the County Sanitation
13 Department for nearly a year and a half. I'm not
14 presently employed with them. That's where I received
15 ray background in solid waste and sludge management.
15 The outfall was extended and the treatment
17 plant was expanded in 1965. Now, less than 15 years
18 later, we are told it's time again to spend more
19 money, more resources and consume more energy in the
20 process. The result would be a new wider, longer
21 pipeline that enables more sewage being dumped further
22 into the ocean, with heavier doses of chemicals.
23 That's the 0D7 plan.
24 Each step of the way. Brown and Caldwell and
25 the Public Works Department claim that this plan is
128
our best choice. The claim is that it's a mere
S30 million for 20 years. That was in 1976 dollars.
No mention of the debt services mat] e anywhere. It's
unclear how much that would amount to, nor what that
cost breakdown would be to ratepayers if the operation
and maintenance costs will steadily inflate. By
nineteen-seventy -- By 1997, some 15 years after the
projected completion of the project, of the first
phase, it will cost nearly $6 million a year, and that
doesn't include land disposal costs; that's simply for
operation and maintenance.
Nothing from the water reclamation or sludge
sales will accrue under this plan. If north coast
farmers pay what they are paying now -- That's roughly
ten cents per thousand gallons -- the City would earn
some $160,000 a year by selling the 5,000 acre feet of
the reclaimed water.
As water use increases and supplies diminish
over the next 20 years, this water's value will under-
standably go up proportionately. Such water use will
detain the need for the go-ahead with the proposed
Zayante Dam.
Brown and Caldwell's Alternative ODlA has
many of the problems as OD7. Other alternatives
addressed by Brown and Caldwell covering reclamation
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arc all the most capi ta 1-he a vy systems imaginable. No
mention of aquaculture or polyculture systems were
mentioned, which are safer, cheaper and provide the
jobs that are absolutely necessary for this town. And
for the people still remaining in the audience, the
unemployment factor is absolutely one of the most
crucial issues involved here, and the businesses that
are blacklisting this community by telling us that
they are going to move and take jobs with them, find
out the next time you negotiate a contract with them
or how many people they have laid off recently, how
much they really care about jobs in this town.
No mention of a hybrid-type system was put
forth by Brown and Caldwell. That would be something
to the effect of upgrading Nearys Lagoon and then
pumping for advanced secondary or tertiary treatment
up at the West Site, the far West Site in Santa Cruz.
They don't have to reclaim the entire 21,000,000
gallons of water. The number I mentioned previous was
the five -- five million acre feet that would take
some five million gallons a day out of the system,
and that wouldn't add that much more cost to the
system.
In the case of Santa Cruz, Brown and
Caldwell contracted to do the million dollar study.
130
The biases, 1
expound upon.
The
study will ke
elusions are
basically a s
have no licen
sewage system
biological se
their alterna
line be given
and a half mi
Caldwell.
Also, they have conceded their bias towards
protecting business interests, as publicly stated at
the educational session for the Santa Cruz City
Council on August the 21st. They believe it's better
that Santa Cruz residents, over the environment,
subsidize business profitability. Proposition 13
savings could be used to pay for a better sewage sys-
tem if — if the need can be shown clearly by business
and that might mean opening up their books. Federal,
state or local loans or grants could help offset
undue hardships in this case to keep the businesses
viable and maintain those jobs.
imitations and inaccuracies I will fur the
major biases include the fact that the
ep them in business, provided their con-
convincing enough. Brown and Caldwell is
teel-and-concrete engineering firm. They
ses to design nor construct alternative
s, as witnessed by failing to include the
condary or aquaculture system in any of
tives. Should the new sewage outfall
the go-ahead, this will mean some five
llion dollars income for Brown and
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funding. In other words, rather than loc.il residents
paying two and a half million dollars for a thirty
million dollar system that would be outmoded before
it's even built, disrupt ecological balances, waste
valuable energy and solar nutrients, the same two and
a half million dollars under that formula which was
previously mentioned could pay for a hundred million
dollar system, if necessary, if it's qualified under
the EPA guidelines.
I realize that it's in a state of flux at
this point on the state level. I haven't talked with
Kurt Wasserman of the Office of Water Recycling, but
the possibility most certainly does exist.
The issue is painted as a choice between
advanced primary and secondary treatment. Before I
mention that, I want to say that the issue of the out-
fall lines was mentioned by Professor Doyle. If Santa
Cruz effluent was cleaned up to the point where it met
EPA standards and with the implicit intent of exceed-
ing those guidelines, there is absolutely no reason
that the outfall lines should have to be built.
As far as the question of primary and
secondary treatment, this points to the fundamental
problem with the entire Brown and Caldwell report.
Future planning sacrificed for short-term expediency.
131
The tannery, the e ( nn , rojil ribnl.
some 15 to 20 percent of the treatment plant's load, an*
that includes the greatest majority of the salts, heavy
metals and other toxicants. There is absolutely no
rcas-jn that they shouldn't pay for what they are puttin<
i n .
Brown and Caldwell left out any mention of on-
site recovery treatment, which requires pretreatment.
Such a requirement for a system such as a tannery would
alleviate vast public expenditures at the treatment
plant end. Such planning would also save energy costs
and in the long run save Salz Tannery's supplies and
materials as those costs rise.
Inconclusive proof -- The -- The -- Under OD7
and 0D1A or B, using the standards of the EPA, the
ammonia discharged will -- will exceed permissible level
by some three or four times. Inconslusive proof has
been presented that safe levels of arsenic and chromium
will be discharged.
In the Draft EIR Supplement, a statement on
Page 1 says that 75 percent federal and 12 and a half
percent state financing can be obtained. No mention
was made regarding implementation of new alternatives
or innovative systems under EPA law which would
qualify for 85 percent federal funding, 12 and a half
percent state funding and two and a half percent local
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Just a few brief points. We are running out
of time.
Table 2-10 in the Brown and Caldwell reportd
not mention OD/RE7 as an option, but then later in the
chapter, they chose it for detailed analysis. It was
quite confusing at that point why that was going on.
Page 21 of the supplement to the -- of the
EPA Environmental Impact Report, "There is still a
question as to whether or not passing toxics through a
biological process —" This is a quote. may
alter the chemical state and therefore detoxify some
wastewater constituents. This question has not been
thoroughly addressed in the scientific literature to
date."
That should be pursued much further.
The issue of why — why inland areas. We
don't have — We are not able to have ocean discharge.
We can't receive such a waiver. That coast areas
should be so privileged as to not have to have to
comply with EPA standards because — it seems rather
ludicrous.
Page 25 of the supplement says that there
will be a surfacing of wastewater — of a wastewater
plume, this being the major issue as best as I can
tell for the -- the need for the outfall line.
136
Even — Even by the extension of the new outfall,
there still would be the -- that wastewater plume, as
Dr. Doyle already outlined, could be a problem for
the -- for the popular seabottom fishing as well as
the marine lab.
I urge you to consider denial of the waiver
and help fund a reclamation program under the new
innovative and alternative clause which would amount
to the 85 percent from the federal government. If a
waiver is necessary, do so on a limited basis as
San Diego is pursuing, or the other possibility as
Monterey is proposing right now. They have submitted
a plan for advanced secondary treatment which will
allow crop irrigation. They have also requested a
waiver on the ground that, in the rainy season, that
they will be able to discharge to eliminate the cost
of secondary when it's not necessary.
Thank you. I will submit this -- I need to
type it up. I have some more elaborations in it, but
I didn't want to take the time right now.
CHAIRMAN WALKER: And you have the address
to send it to?
MR. POMERANTZ: Yes.
CHAIRMAN WALKER: Thank you.
MR. POMERANTZ: I believe I forgot to
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mention for the record that I wasn't speaking as an
individual, but rather for the Santa Cruz Urban and
Energy Services Task Group.
CHAIRMAN WALKER: All right. Thank you. We
have that on the card.
Glenn Specht?
MS. GLENN SPECHT: My name is Glenn Specht,
and I live in Aptos. And I'm speaking for myself this
evening, but in the past, I have served as a Director
of the Aptos Chamber of Commerce and on the county's
both wastewater and solid waste studies, and I have
served the Santa Cruz Sanitation District as the
President of the Citizens Advisory Committee.
I'm first of all glad to see that we finally
have a draft report that does have numbers on the
pages because some of the early reports didn't, and it
did make them interesting to go through. However, I
find that my comments and concerns are very nearly the
same now as they were four or five years ago. I know
that it may not be under EPA's control, but I still
find it hard to believe that we may dump untreated
water into a septic tank, and within the same small
property, take it out of our well and use it, but we
cannot treat water to any degree, percolate it through
specialized prepared soil and then reuse it.
138
I like percolation. I think it's the most
totally plausible way of reclaiming and rousing our
water and recharging our groundwater system. And I
think rather than always saying that the state is
at fault because they won't let us, we ought to aet
busy and kick the State of California into letting us
do some of these things.
I always have a picture when it rains of some
fellow with a sign saying, "All dirty water to the
right" and "All clean water to the left," and that's
what keeps our groundwater pure.
I would like to mention in regard to the
report itself that I find some problems with the
statistics, which leads me to believe that there may
be other problems with the statistics and put the
entire report in doubt.
For instance, I can tell you that the esti-
mated population of the Aptos community of 14,000 is
absolutely and positively wrong. For exactly that
area recently, I have had reason to count the regis-
tered voters, and I can tell you that there are more
than 9,000 of them within that area, which you say has
a 14,000 population.
Now, the State of California has a formula
that gives you a population estimate based on
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registered voters that says multiply registered
voters by three, and that gives you 27,000 people.
Well, that is an average formula for the State of
California. And granted that the people in Aptos may
be a little more responsible and have a little more
registered, it still is hard to believe that with
9,000 plus registered voters, there are only 5,000
children under the age of 18 and nonregistered voters
in the area. I think something is wrong with the
figure.
If you take a look in the same area of the
land usage in institutional usage, and that's schools
and churches, you have 140 acres.
Well, gentlemen, Cabrillo College is in that
planning area, and it has 120 acres. There are two
elementary schools, about 11 to 20 acres apiece, and
a junior high school with 20 plus acres, and there are
ten or more churches from one to seven acres. And if
Aptos High School is included in that planning area —
And I do believe the line goes near, but perhaps not
to it — there is another 60 acres.
In other words, I have identified rather
handily that you have about a 50 percent problem there,
and there are at least probably another 150 acres that
you haven't counted. And I believe there are some
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14 0
problems with some of your other Aptos numbers.
Now, I'm not paranoid enough about Aptos to
think that you only make mistakes in Aptos and that
more precisely the sources of your numbers only make
mistakes in Aptos. I think that source probably lies
in the fact that the special census of '76, and per-
haps even in the 1970 census in this county, does not
appear to be as accurate as it should have been. What
ever the cause is, since these figures do have to do
with the projections of usage and volumes concerned in
the plans, I think that they need to be looked at a
little bit better.
I also have some problems with the funding
figures that are considered when it comes to reclama-
tion. It's not exactly clear, and perhaps you are
subtracting from the costs of reclamation first what
it would cost to throw that water away. In other
words, since you are going to have to treat it to a
degree before you throw it out into the outfall to
start with, that amount of cost of any reclamation
program certainly should not be laid back on the
bar of reclamation.
It's also obvious to anybody that you are
not going to be able to reclaim the total volume
going through the plant and, therefore, do not need to
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l i i-.iL to t'cclaiii.iLioii s 1 a nda nl s llio toi.il volume* going
through the plant. And I would certainly hope that
your reclamation figures reflect not then the cost of
total treatment of all waters to reclamation standards
but only treatment of those waters that will be used
for reclamation to reclamation standards.
I should also hope that those figures reflect
costs recoverable, certainly not any -- at any more
than the growing -- the going rate for water. I would
not ask anybody to pay me more to use reclaimed water
than they might have to pay to use Soquel Creek, etc.
But those costs are recoverable and should be figured
into the cost of reclamation.
I think if at that point you compare it with
what it*s going to cost to generate clean water
sources to provide these same waters, I think that it
comes out quite economical, in fact, to consider
resource reclamation, particularly in the area of
water.
I have got to say that I have been a little
concerned for a great many years about the institution
arrangements, and I know this EIR has to do with the
plan itself, but still I think the institutional, the
governmental arrangements that control it are some-
thing that have an effect, at least to the political
142
and financial en viron im? n L of my commit n i L y . Tit i s
supplemental report is done by the City of Santa Cruz.
The project is funded through the City of Santa Cruz.
I should like to remind you that the majority of the
people who both are funding sources, because this is a
regional project, and who use this project do not live
in the City of Santa Cruz, and with the current insti-
tutional arrangement, we have very little if any say
in the eventual quality of running the decision-making
process that has to do with whatever kind of facility
you eventually decide we may have. And I should like
to give you an example of that.
I should very much not like to be at the
mercy of the industrial businesses of the -- of the
City of Santa Cruz and the pressure they put on the
City of Santa Cruz to come up with the kind of treat-
ment and treatment plant that it seemed best for their
needs. And I have always been under the impression
that the EPA was everywhere, so it seems very unlikely
to me that any of them are going to find it financiall\
feasible to totally give up their location, their
building, etc., and start anew someplace else and
find actually any better circumstances that have to do
with their wastewater than they are going to find
right here, particularly coming new into any community.
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So I really find that, you know, a bad argument in a
couple of ways.
I should also like to point out, as far as
environmental impacts are concerned, that a lot of
impacts are more or less temporary. And, for instance,
if you should decide that the water needs to be shippec
south to the south county# that since it -- a lot of
it managed to get here across all those same creeks
and rivers from Aptos to Santa Cruz, it probably can
manage to get back again with the same minimal end
effects.
Likewise, concerning the salamander, there is
a large part of the year where the dear creatures are
up on the freeway. You probably can dig through them
without bothering them at all. But I believe the
route to be used is down to the freeway, and in that
case it is only warm-blooded creatures that you will
disturb, and they will cool off after a while.
I think that there is just c>ne thing that 1
would like to add. There is an industry which does
have an impact both on water usage and water quality
which does not seem to have gotten mentioned, or at
least not where I was reading. Commercial laundries
and/or water softeners have a couple of impacts. Not
only are they great water users and returners of
14 4
waters to the waste stream, but they are responsible
for a great deal of the salts, the nitrates in the
waters, and — and that you will find the president of
their association at almost any Water Quality Control
Board meeting making sure of their interests because
they are very much concerned that they not be refused
the freedom of back-washing salt-activatod water
softeners into the wastewater stream. And it seems to
me you might eliminate some of the very costly clean-
ing up of wastewater by eliminating the dirtying of
it in the first place. Every time your Culligan man
makes a call to your block, he is polluting badly.
And it seems to me that either a reclamation program -
And there is a way of reclaiming those solvents by
going to a charcoal filter, which is a way of saving
the general public a great deal both in water resource
and in funds.
And I might add that the people who choose
to soften their water are the ones that should pay
the cost and not the rest of us.
Thank you.
CHAIRMAN WALKER: I observe that the hour is
now past 11:00, and I think the young man here taking
everything down is entitled to a short recess. So we
will recess now for ten minutes until 20 minutes aftei
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i1:00.
(A recess was taken from 11:10 p.m. to
11:20 p.m.)
CHAIRMAN WALKER: Well, ladies and gentlemen,
we still have some work to do, so let's go back on the
record.
During the recess, I had several inquiries
about how we are going to proceed here this evening.
I have five cards here left of people who wish to
speak. I earlier announced --
Am I coming through back there?
FROM THE FLOOR: Yes.
CHAIRMAN WALKER: I earlier announced that
wc would have two innings of this hearing. Innings 1
was to talk generally about everything on the subject,
and Innings 2 was to talk about the special supple-
mental report. Up here on the panel we sense that
people have pretty generally been talking about the
supplemental report along with their remarks on the
general report.
After these five people have been called and
they have had their say, we will conclude the first
part of this session, Innings 1, and then we will
open it for the second part solely on the supplemental
report. We will consider on the supplemental report
in
all of the remarks on that siibjoct that have already
been made, so it will not be necessary to repeat any-
thing. If anybody out there has been saving some-
thing to talk about for the supplemental report, at
that time we will hear them then. I have a suspicion
that everybody who has been called or will be called
will have said what they had to say already. However
we will give you that opportunity.
Now, at this time we will go on with the
program, and the next card is Charlotte Melville.
MR. VAN ALLEN: Looks like she left.
FROM THE FLOOR: It's past her bed time.
CHAIRMAN WALKER: She may be outside.
Charlotte Melville, the second time of asking. Evi-
dently not. Charlotte Melville, last call.
Robert Hall? He's been waiting a long time.
MR. ROBERT HALL: I know the evening's
getting late. Thank you for the opportunity of speak
ing.
I'm Robert Hall. I live in the City of
Santa Cruz.
Under the present limitations on tax spend-
ing, it's difficult to see how the City of Santa Cruz
can justify the spending of upwards of fifty to a
hundred million dollars on sewage disposal and water
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sloi.njo. Proposals would undoubtedly require? bond
1
of Sanlo Cruz during both 1 lie advisory .mil in.iriil.il ory
elections. Many consider this a further tax on an
2
water rationing, it was surprising that no mention of
area now considered the seventh in rate of growth of
3
water conservation, or very little except for past --
counties of the nation.
4
the past drought, education -- or education in the
Alternatives such as wastewater reclamation
5
water usage was mentioned in the water supply esti-
and alternatives for water storage have not been given
6
mates study of August, '79.
much consideration by commissions dominated by engi-
7
Sources of point pollution were mentioned
neers and specialists in wastewater disposal. I
8
tonight as detrimental for secondary sewage treatment
believe that they have overlooked many opportunities
9
and as a justification against secondary treatment.
to look into alternatives.
10
and nobody mentioned, the cost of our continued wastage
Little mention was made, for instance, by
11
of what we very glibly term wastewater. This is
¦the people for an advanced primary treatment plant
12
another and perhaps yet another high dam on our -- one
and outfall into the ocean or the concern of another
13
of our beautiful streams may solve this problem, but
group represented here also for a big dam on the
14
I doubt it.
Zayante Creek. Likewise, the high dam people made
15
By addressing the above issues separately,
little or no references to methods of conservation
16
we will only continue to delay the time when, by
dealing with recycling of wastewater. Conjunctive
17
applying modern technology, we can beqin to work with
water use, intradistrict ties, was barely addressed
18
the natural cycles, working with nature instead of
while intradistrict sewage plants were amply justi-
19
putting off the day of reckoning.
fied by the report before you.
20
On every hand we hear the cries against
Among the many uses for wastewater recycling
21
big government and needless bureaucracy, and yet those
mentioned at the hearing August 20th were highway
22
who are advocating these plans are bringing in the
beaut ification, river bank planting and reforestation.
23
Corps of Army Engineers and other large governmental
floraculture and agriculture and the greening of our
24
entities to do that.
proposed greenbelt. Considering the exemplary model
25
Now, I'm not against big government because
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wo are going to need to — to utilize some of the
financial resources, but I think we have to consider
this .iinon
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will hand in a copy of your remarks, we will mark that
as Exhibit 21.
(Whereupon, Hearing Exhibit
No. 21, statement of Robert
Hall, was incorporated intc
the record.)
CHAIRMAN WALKER: The next card is Mr. Bill
Quealy.
MR. BILL QUEALY: Hi. Bill Quealy, speaking
on behalf of the nutrient group that was formed in
hopes of developing a reclamation plan for Santa Cruz.
Now, the Brown and Caldwell plan conflicts
with three county study recommefidations to explore
ways of reusing wastewater in Santa Cruz. Some of
these studies were released after you would have had
time to consider their impact upon the wastewater
facility plan. These studies are:
The watershed study plan;
The Community Resource Agency's '77 Environ-
mental Report; and
The Agriculture policies of Measure J, which
calls for increasing the availability of small farms
in Santa Cruz.
The watershed study plan most recently
released, *79, states wastewater could be used for
gardens, parks and large land irrigation. Increased
152
use of wastewater on the north coast where there is
more agriculture or in Santa Cruz could reduce the
City's dependence — demand for water from the water-
shed.
Wastewater should be utilized wherever
feasible. It should also be insured that the waste-
water is retained in the watershed as much as possible,
current in-basin disposal of wastewater.
The EIR states that septic system failures
are primarily due to adverse groundwater conditions,
but the watershed study plan suggests these failures
are, aside from people needing new systems, the result
of leach fields being too low for the root zones of
plants to clean the water. That's tertiary treatment.
Rather than recommending removal of septic
systems in the valley and hook everybody up to the
dam, it would seem more appropriate to revegetate the
area.
Tertiary treatment of wastewater by a healthy
watershed. It should be noted that the public dis-
cussion on the waiver application was foreclosed by
our Mayor before all the public coming to testify
could speak.
Tertiary -- Tertiary -- Secondary treatment
would require polluting industries to contain waste on
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site. And I haven't seen that -- a cost comparison
1
whore these industries might actually be able to save
2
money containing industrial intoxicants rather than
3
paying the yearly proposed sewer rate through their
4
wastewater facility plan.
5
Last week Brown and Caldwell, at the City of
6
Watsonville, claimed public reclamation would be
7
included, but no discussion. One of our nutrient
8
group was able to shout at them.
9
There was a hyacinth proposal for Santa Cruz,
10
for which there were no EIR, and at which many ques-
11
tions were left up in the air.
12
Potential ¦ for reclamation. And Santa Cruz is
13
in a decentralized pilot projects program that com-
14
bines a variety of alternatives at various sites
IS
throughout the county. These are like five different
16
legs of a table. What Brown and Caldwell has done for
17
our city is to show how each leg of reclamation by
18
itself could not hold up the table and capacitate for
19
enough wastewater in order to meet the need for an
20
outfall extension. Such a reclamation plan would
21
require a joint agreement between the city, the county,
22
local public and private agencies, farmers, individuals
23
developers and industry.
24
During the drought, Santa Cruz was able to
25
154
save more water than any county in
local sun exhibit won statewide ac
one can see in this the potential
ment and conservation.
Santa Cruz does not have
tive. Brown and Caldwell cannot t
water seriously since they are the
recommending a dam for Santa Cruz
called the Water Resources Study.
What was the name of that
DR. DENNY S. PARKER: (Br
You are referring back to the '63
Master Plan?
MR. QUEALY: Yes.
DR. PARKER: I think that
MR. QUEALY: The Water Master Plan. This
wastewater plan is economical and Counci1,members who
don't have to deal with all the people between the dam
and the outfall can come up with a more sophisticated
circular system. But it certainly is economical for
the other county.
More water and nutrients out to sea. Now,
according to the Assistant Administrator of EPA,
Thomas Jorling, said a recent publication on sludge
land disposal regulations or regulations for sludge
the sUto. Oil r
claim. Surely any-
for energy develop-
an adequate alterna-
ake our need to save
same firm that is
in a separate report
again?
own and Caldwell)
report, the Water
•s it.
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would be ready on September 1st. That's in two days.
The hurdles for reclamation in Santa Cruz
thnt were mentioned earlier this evening, T don't see
any problem with those, with a ten-foot vertical
zone or one-year percolation. These are things that
haven't even been looked at, let alone pushed aside.
Total dissolved solids on site can be taken
care of through on-site industrial containment, and
this should lower the expense of waste reclamation.
I don't see any basis for the 422 to 719
per acre foot estimate.
I also felt the EIR left out the effect of
household and domestic plans being developed for salt
water toilets and regional septic systems. This would
in effect, lower the expected rate of sewage flowing
into the Santa Cruz plant than is determined by a mere
population increase. The population would increase,
but expected flows of sewage are reduced by a per-
centage.
Thank you very much. -
CHAIRMAN WALKER: Thank you, sir. Do you
have a copy?
MR. QUEALY: This I will have to send in
because I have been jiggling all over it.
CHAIRMAN WALKER: You will send it in. Thank
156
you.
Mr. Tony Ryals?
MR. TONY RYALS: Good cvt-nincj. It's been a
while but, anyway, 1 live up in the Valley where the
dams are built when the outfalls are expanded down
here, and so I thought I would come and give my two
cents.
We have heard about the water hyacinths in
Bay St. Louis, Mississippi, and the Solar Aquasystems
in California reclaiming -- actually reclaiming waste-
water. There have been experiments conducted in this
regard at Louisiana State University. I have done
volunteer work with algae in sewage lagoons. There
are also people working with barley and seawater which,
of course, you could even flush a toilet with sea-
water. You know, we are not -- just not doing what we
have to do.
And, anyway, I'm for — I'm speaking for the
Nutrient Energy Resources Committee. We, for one,
want you to consider the toxicity of chlorine and its
impact on ocean or land disposal very seriously.
Alternatives such as ozone, pa s t eur i za t ion , ultraviolet
radiation and degradation by beneficial organisms,
that is microbes and plants — Max Planck did work
with that, you know, different things -- have not been
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adequately considered as alternatives to chlorination.
The use of chlorine is suspected of numerous environ-
mental problems, from carcinogens in drinking water,
of which New Orleans is a prime example, to the
possible oceanic toxicity to seaweed or animal life.
While dechlorination of chlorinated wastewater has
been alluded to, the environmental and economic
impacts of dechlorination probably make alternatives
to chlorination attractive.
It is crucial to note that, if we are foolish
enough to persist with chlorination anyway, that pri-
mary sewage treatment requires more chlorination of
wastewater than does secondary, and primary produces
more potentially toxic chlorinated hydrocarbons.
Next, we would like you to pay particular
attention to the outfall's environmental and economic
impact on water supplies. We already have serious
water supply problems and feeding a larger outfall
will add to the stress on our supplies, including
necessitating of sizeable damming operations.
The costs, both environmental and economic,
of the $25-50 million Zayante Dam must be considered
as part of the outfall's impact.
Last, but far from least, we must go on
record to insist that your EIR's, whether for primary
158
or secondary standard treatment, or whether here in
Santa Cruz or elsewhere in this United States, begin
to consider the environmental impact of ocean or rive
dumping of wastewater or nutrient-loaded sludge, mis-
management, with the environmental impact of such
fertilizer mining as the Florida phosphates and the
radioactive slag wastes it produces -- And I'm sure
you know about that, but you have got to start adding
the two, the Florida waste, that the outfall is the
phosphate — No joke — plus the energy and environ-
mental problems its continuous transport into our
county means relative to recycling. As Isaac
Azimov. said, the noted scientist and chemist,
that we are in the end, and we might as well start
now. In fact, we need these elements to get carbon,
which we are pleading just to mine it away. Throw it
to the ocean. Where are we going to get the energy t
get it back after we have already consumed the energy
and we need it to give us the carbon?
Surely, if you did consider this impact of
the environmental slag, etc., the energy we need from
the phosphorous in the future -- The phosphorous in
the soil is like money in the bank. It's like an
investment. But if you throw it away, you have no
money. You have no capital, and you will not get a
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re turn.
Surely if you did consider Ihe importance of
this phosphorous, you would — and all tliono nutrients,
you would begin to see the importance of making bio-
logical tertiary treatment, or the cleaning of waste-
water with living plants, such as aquatic plants,
trees or annual crops as a priority in the use of the
billions of dollars you presently dole out for non-
cyclic dumping.
Thank you.
CHAIRMAN WALKED: Thank you, Mr* Ryals. Do
you have a copy of your remarks that you would like to
hand in?
MR. RYALS: Yes. I will give you a ratty
sort of thing and a paper on greenbelts in Santa Cruz
or just a bigger outfall.
CHAIRMAN WALKER: Thank you. Your diction vat
a little fast.
This will be marked Exhibit 22 and 23.
(Whereupon, Hearing Exhibit
No. 22, three-page docu-
ment entitled "Nutrient
Recycling Greenbelts in
Santa Cruz or Just A Biggei
Outfall?," was incorporatec
into the record.)
(Whereupon, Hearing Exhibit
No. 23, statement of Tony
Ryals, was incorporated
into the record.)
160
CHAIRMAN WALKRIi: Mr. .U-rry Ihisi: h?
MR. .IKRIiY HUSC11: My name is Jorry P.usch.
I'm wi l.h 1 ho Ct ernbcl t Commi t tcr , nnel I'm also the
Editor of the Environmental Council Newsletter.
1. The EPA's own criteria for assessing
whether or not to grant a waiver of socondary treat-
ment requirements are -- They stress two primary con-
cerns.
One, the cost of secondary treatment; and
Two, the impacts on marine ecosystems.
I believe the language is that you are to
maintain a, quote, balance in the marine ecosystems
into which you are dumping this primary effluent.
The -- Neither the draft EIS/EIR nor the
supplemental EIS/EIR adequately addresses the impacts
on the, quote, balance of the marine ecosystems into
which you are dumping this effluent. I quote.
"Given the present state of knowledge, it is
not possible to predict in any quantitative sense
the overall ecological impact of wastewater dis-
charged in marine waters."
I quote again:
"The environmental effect of the present
Santa Cruz outfall is not known."
I quote again:
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"Some species may suffer; others may profit
from the toxic constituents present in the waste-
water, not all of which are even known."
I could go on. You are not proving that you
are not disrupting the balance. You are not proving
that you know this for even secondary treatment. It
could well be that you are not justified in dumping
in effluents, any increase at all over the present
dumping. In other words, given your criteria for
maintaining a balance, the burden of proof is on the
lead agencies to prove that you are not disrupting the
balance of these marine ecosystems. And you have not
done that, given the draft EIS/EIR. Clearly you have
not done that.
The intent of the law is to place the burden
of proof on you. I reiterate.
I would also point out that Monterey Bay is
being considered as a marine forum or marine sanctuary
status and that Alcorn Slough already has estuarine
sanctuary status, or is very close to having that. So
all of these -- So these are — are valuable wetlands
which could be impacted by the toxic constituents
that are in the wastewater.
I would also add that surface water currents
during certain parts of the year -- January through
162
1 April, I believe it is — will bring plumes of waste-
2 water, directed plumes into Monterey Bay, which has
3 been -- which is admittedly a much more closed system
4 than the much larger Pacific Ocean basin into which
5 you are trying to direct the wastewater.
6 And, finally, secondary treatment should be
7 considered, not just to prevent impacts on marine
8 ecosystems, but as a prelude to the possible treatment
9 of the water through biological tertiary methods and
10 eventually land-based disposal. It may not be that
11 we have the technology now to dispose of water, but
12 we need to prepare ourselves via tertiary treatment so
13 that we do have the technological capacity to treat
14 water sufficiently for crops and drinking water
15 aquifer recharge.
16 And that's the extent of my statements this
17 evening.
18 CHAIRMAN WALKER: All right. Thank you, sir.
19 I now have no further cards before me of
20 people who have requested the opportunity to address
21 the panel. Is there anyone who filled out a card and
22 marked the box saying that they wished to make a
23 statement and the card has not reached the podium? I
24 see no one arise.
25 Is there anyone who did not check that box anc
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who now lus decided Lhey do wisli lo nuke a sl.itcinont?
I r.oc no one arise.
I qucsSi then, we have come to th.it part of
at least the first part of the program. So, in
accordance with the procedure that we previously
announced, we will adjourn this part of the public
hearing concerning the Environmental Impact Statement
and the Environmental Impact Report that was marked as
Exhibit 2. That's the large volume. We will keep the
record of that hearing open for two weeks, which will
be the 12th of September. So anybody who wants to
make written remarks should send them to the Environ-
mental Protection Agency, 215 Fremont Street, San
Francisco, California 94105. It will assist if you
will nark it somewhere "HE-154." That's the mail code
for this hearing. They must be received before the
close of business on that day to be considered a part
of the record.
After the record is closed, all of the
material will be assembled, all of the remarks that
we heard here tonight, all of the correspondence that
we have received or will hereafter receive, will be
put together into a file, and it will be carefully
perused by a number of staff people. Briefing docu-
ments will be prepared on that and, in a sense, the
lf» 4
decision is a eolloyial one in t. IkiI iw.iny [u'i-|iU'
participate in it.
Eventually the (Incision in mndr by the
Regional Administrator. He essentially does this on
the basis of recommendations made to him by his staff.
I do not know — I can't tell you tonight
how long that will take, but ultimately this decision
will take the form of a final Environmental Impact
Statement and accompanying Environmental Impact Report.
This is required by the law before a grant offer can
be made.
That is the way in which the agency will
respond to all of the remarks that have been made
tonight or will hereafter be made in writings.
Now, having said that, we will then close
Innings 1 on that part of the hearing. We will now
open the hearing on Innings 2, which is the supple-
mental report prepared by Jones & Stokes Associates
for the City of Santa Cruz. Although I will continue
to preside, this part of the meeting is a hearing
under the California Environmental Quality Act, and
we are to receive comments on this new supplement.
We have determined that the previous speakers
on Innings 1 have pretty much addressed this subject.
If, however,.there is anyone who has new information
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that hasn't been said before, you have been sitting
back Ihere holding back on that information and you
w.i n t to toll it to us now, this is the time.
Is there anybody out there who has something
new to say on this subject that hasn't been said
be fore?
MR. RONALD POMERANTZ: Can I ask a point of
information?
CHAIRMAN WALKER: You can ask a question if
you give me your name.
MR. POMERANTZ: Ronald Pomerantz.
What I was wondering is if the comments from
the previous Inning 1, as you call it, are going to be
incorporated into this latter half of Inning 2?
CHAIRMAN WALKER: Yes.
MR. POMERANTZ: I didn't hear that very
clearly.
CHAIRMAN WALKER: That is exactly what I
mean. You do not have to repeat it again.
MR. POMERANTZ: Okay. Thank you.
CHAIRMAN WALKER: We heard it once. We have
got it in the record. We can use the record for both
purposes.
Yes, sir? Your name?
MR. DAVID BOCKMAN: My name is David Bockman.
1 66
I'm speaking for the Santa Cruz Kivjiona] ijioup of the
Sierra Club.
T don't have those cr> mmc n t- s in writ inq,
either, but I will try to submit them in writing
before your deadline.
I might make some comments with reference to
the supplement to the Draft EIR.
On Page 19 in the end of the first paragraph
there, it reads -- states, ". . . as described in the
SWRCB's revised Ocean Plan."
"SWRCB"is the State Water Resources Control
Board.
The last I heard was that the Ocean Plan as
originally adopted by SWRCB was approved by EPA but
not the revised plan. I would like some clarification
whether the revised ocean plan was accepted by EPA and
whether or not it can be considered in this document.
Many of the statements in this supplement are
incomplete. For example, on -- on the same page and --
and on, it basically states that the solution to
pollution is dilution. And, of course, this sort of
vein goes through the Draft EIR/EIS itself. And
whereas perhaps some more detailed discussion should
be put in this draft supplement regarding the total
amount of pollutants entering the biosphere, not just
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167
dealing with the concentrations of them.
Dr. Doyle mentioned that he thought this
primary treatment was sufficient, but he didn't go
beyond the questions of -- of, say, what might be
found in a so-called clean primary effluent and the
potentials of certain toxicants and their impacting on
the -- on the marine biosphere.
I believe there is substantial information
in the scientific literature of — of impacts off
the -- the Atlantic Coast. I remember reading some-
thing about impacts off Miami where fish were observed
with tumors, etc., and the comments were made that
they were potentially from ocean outfalls and con-
centrations building up of carcinogens in the marine
biosphere, and Dr. Doyle indicated that there were
periods of the year, which is obvious here off this
coast, that the point where the outfall would be
located would be in fog. In fact, it could occur
many weeks without any break in the fog. And so they
receive little sunlight, and, at that time of the
year, these pollutants could concentrate in that area
Nor is it indicated here in the report in
terms of storms what sort of inflow toward the shore
this would occur.
We have heard a lot in terms of drinking
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168
water regarding the build-up of carcinoyc-ns in the
water to dechlorination, presumably resulting from
increased cancer rates, for example, in the City of
New Orleans, and this has been traced to chlorination
of waters that were treated for -- taken from the
Mississippi River for the City of New Orleans and, as
a result of certain EPA requirements, I guess that
have not been fully carried out, for charcoal filtra-
tion, activated charcoal filtration of drinking water
to remove chloroform specifically and apparently
additional carcinogens that may be in the water. Pre-
sumably this chlorination that's occurring here, would
be occurring in the primary treatment system, would
also create carcinogens and they would enter the bio-
sphere. The chlorination would have already sub-
stantially occurred before the oxidation had taken
place.
These may be very small amounts, but they
can be built up in the biosphere.
There is discussion of certain -- in the
supplement of certain questions of chronic toxicity
which I dwelt on a little bit here in the last section
I remember reading not too long ago of a build-up of
cadmium in sea otter tissue. Sea otters are found
from off San Luis Obispo County north to Santa Cruz
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) f.y
. i n • I m * w :|i.iii I Point San 1 a
1'iuz and, in fart , I li i;; spring I lioro war: a birth of a
i» M i• i oil o ( 1. i a t cnod -ijicc i o:; ,
and ronsiiloral i«n will h.ivc to bo given to a relatively
f.m.U 1 n mount of these toxir.inls that can build up in
I he food chain and impact on m/trine ma mina 1 n,
ospec i a 1 1 y a marine ni.imma 1 like the sea otter that is
i-onfinod lo a very narrow band near the shore.
Mcnl ion was made of — of tho estuarine
r.ancluary propor.nl r.. There is a proposed estuarine
:;anrtuary for Alcorn .Slough that the final KFS has
boon issued by lho National Oceanographic and
Al mospherio Administration about a couple of weeks
ago. The Draft KIS on tho proposed marine sanctuary
is under preparation at this point by the National
Oceanograpli ic and Atmospheric Administration, and it
qoo r, substantially beyond Moni oroy Bay. ft extends
from the f»an Luis Obispo county line north to the
fian Mateo County lino and includes — surrounds the
waters where the proposed outfall would go. So there
1 7 0
?: ho\i .1 d be s oiue ;; u t>s I a n t i a I nu j i e «l i s«• \i s i (. n mi — on
the -- the pot.cut ial confl i c t r. between the i:reation oJ
.i in. i i i ne sanctuary and this nee .i n outfall, and also
impacts on proposed estuarine sanctuaries during
portions < > f I he year of the flow is in A1 cor n S 1 ou g h ,
which is a very important area for — a:; a .spawning
grounds and for a nursery for a wide variety of marine
life that — that actually enters the ma r i no system
at later t imcs.
On Page 23, a discussion of "General
Ideological Impacts," there was substantial studies
during the operation of the outfall at Soqucl Point
and discussing the — the — the diversity of species,
animal and plant species at that point in comparison
with a -- with a relatively clean -- clean areas at
some distance from it, and there arc indicated a wide
difference in the -- in the species and diversity at
Soqucl Point to -- to other points. Perhaps there was
a high concentration of the red chlorine algae at
Soqucl Point. Obviously, the concentrations at Soquel
Point would not be the same as at the ocean outfall as
proposed under this alternative, but I think there is
information available indicating that there -- at
least at certain outfalls, there can be a significant
impact on — on species diversity, and it's not
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171
discussed here.
On Page 25 it indicates under this alternativ
1ti.il I li e vfil uiui' of slmlnc will double f ruin 4 0 Inns per
day to 80 tons per flay relative to the secondary treat
ment system, but it does not discuss the impacts of
this. This sludge would have to presumably go to the
city's disposal facility which is nearby here and
which will eventually — at this point in time, this
facility has had to have one or more warnings from
the Regional Hater Quality Control Board to have a
substantial system for controlling leachate from
entering a creek that flows through the city.
Indications in testimony -- from testimony
from a representative from the State Department of
Parks and Recreation are that that facility would,
even after it's closed, continue to leach material,
continue to leach from that facility and will have to
have a leachate control system.
A new state park will entirely surround the
city's sludge disposal site as projected here. There
should be substantial discussion of impacts in the
long term — short-term and long-term impacts of
increased sludge disposal at that site. There should
be a discussion of relative problems with odors
regarding this primary treatment, continued primary
172
1 treatment, and the secondary and the tertiary systems.
2 Tile Solar Aqunsyslems proposal is an enclosed system
3 when (Mint:-. .Ill' rnMUMl or :;ueh I 1ml there a i e no ]uo-
4 jectod odor problems from that system. Hut there is
5 no discussion here of that, and which I think should
6 be -- can be discussed in -- in -- in -- and should be
7 discussed very thoroughly.
3 That's all I have. Thank you very much.
9 CHAIRMAN WALKER: Thank you, sir.
10 It's been pointed out to me that I did not
call on the consultants when we opened this Innings 2
12 to see if you had any additional comments to make or
descriptions over and above what you already had said.
MR. MILLS: Well, I think that everybody has
been talking about 0D7 so much that you probably all
know what it is, so I don't think I would have to add
anything. It's the same location, Nearys Lagoon;
primary treatment facilities, would improve chemical
feed addition. The outfall, the same as we proposed
for 0D1A; alignment 1C. Much reduced cost is about the
only thing I might point out.
If I can find those cost tables, the one that
I couldn't refer to before.
Has a -- 20 years of O&M capital, an O&M in
1976 dollars of $30 million. So it's again about a step
13
14
15
16
17
18
19
20
21
22
23
24
25
-------
173
of fifteen million or so below 0D1A.
And I just might show what the cost is to the
homeowner of these two cases.
Now, this -- all the costs we have been
pointing out so far are costs in 1976 dollars. These
costs are escalated by a variety of inflationary
factors, depending upon the component you are talking
about, to 1982-83 figures. This appears in Appendix
F, which is a separately bound project to the project
report, which is in the library. These include all
the existing charges for both systems as well as any
charges that might be pertinent to the proposed
expansion. So you can see the relative ranges here
for the two alternatives and for the two jurisdictions
I think that's all I have to say.
CHAIRMAN WALKER: Thank you, sir.
Is Mr. Rushton here? Do you have anything to
add?
MR. RUSHTON: I don't think I need to really
add to what has already been said other than the fact
that the 0D7 alternative impacts are basically the
same as what I discussed for the NP2 alternative
earlier. The chemical additions would be slightly
higher and the costs differences have been pointed out
by Mr. Mills. Basically, it's the same alternative.
174
CHAIRMAN WALKER: Is there anyone rise in the
audience who has remarks that are directed specifica11
to the Santa Cruz Wastewater Facilities Plan? Other
remarks that have not been made before? I see no one
arise.
Do you want to keep your record open for two
weeks?
MR. FIEBERLING: Ves.
CHAIRMAN WALKER: All right. The record in
this matter will also be kept open for two weeks for
second thoughts, after thoughts, additional thoughts,
whatever you want to send in. And those remarks,
however, should be sent to the city. To you, Mr.
Fieberling?
MR. FIEBERLING: Yes.
CHAIRMAN WALKER: Do you want to give them
the address?
MR. FIEBERLING: It would be to the City of
Santa Cruz, 809 Center Street 95060.
CHAIRMAN WALKER: To your attention?
MR. FIEBERLING: To my attention, yes.
CHAIRMAN WALKER: And you all know who he is,
or you can read his name tag.
Very well, then. I will want to add this:
that I am impressed by the audience that came here
-------
175
! Ii i;; evening. It's b
-------
Appendix B
LIST OF PROJECT BOARD OP CONTROL AND
INTERAGENCY ADVISORY COMMITTEE MEMBERS
289
-------
Board of Control
R. Bain, Jr., Brown and Caldwell (exp. June 1977)
P. Baldwin, Supervisor, County Flood Control District
(eff. January 1977)
D. Caldwell, Brown and Caldwell (eff. July 1977)
J. Cooper, Director of Public Works, City of Watsonville
(alt.)
D. Dawson, Supervisor, County Sanitation District
(exp. January 1977)
W. Fieberling, Director of Public Works, City of Santa Cruz
D. Forbus, Supervisor, County Sanitation District
(exp. January 1977)
R. Jones, Jones & Stokes Associates, Inc.
M. Liddicoat, Supervisor, County Sanitation District
(eff. January 1977)
C. Melville, Council Member, City of Santa Cruz
H. Nelson, County Sanitation District (alt. eff. January
1977)
C. Palmtag, Council Member, City of Watsonville
G. Patton, Supervisor, County Flood Control District (alt.)
D. Porath, District Engineer, County Sanitation District
Interagency Advisory Committee
L. Butler, Jr., State Solid Waste Management Board
D. Daughters, Department of Public Works, Santa Cruz County
W. Doyle, University of California Santa Cruz, Coastal
Marine Studies
L. Erwin, Department of Public Works, City of Santa Cruz
J. Goni, Regional Water Quality Control Board
H. Greene, U. S. Geological Survey
S. Hansch, Central Coastal Commission
W. Helphingstine, Environmental Protection Agency (from
January 1977)
M. Jacobs, Santa Cruz County Planning Department
R. Johansen, Santa Cruz County Watershed Management
J. Liebster, Association of Monterey Bay Area Governments
J. Nighswonger, Regional Water Quality Control Board
P. Nordstrom, State Water Resources Control Board (from
March 1977)
L. Pearson, State Water Resources Control Board
D. Pierce, University of California Santa Cruz, Coastal
Marine Studies
S. Russell, City of Santa Cruz Planning Department
R. Talley, Santa Cruz County'Department of Environmental Health
N. Webb, Plant Superintendent, City of Santa Cruz
290
-------
Appendix C
ORIGINAL LIST OF PROJECT ALTERNATIVES -
IMPACT ANALYSIS AND SCREENING RATIONALE
291
-------
WASTEWATER MANAGEMENT ISSUES AND ALTERNATIVES
Alternative
number®
Summary system description
Issue
b
Santa Cruz wastewater
Other wastewater
I. Ocean disposal vs
land disposal
LDj
£
Secondary treatment , storage,
land disposal
n/a
RE j
Secondary treatment6, phosphorus
removal, filtration, demtneraliza-
tlon, disinfection, storage,
distribution for all irrigation uses
In the Pajaro Valley
n/a
ODj
c
Secondary treatment , disinfection,
ocean disposal
r./a
II. Participation oi
food processors^
OD/LDj
Secondary treatment0, disinfection,
ocean disposal
Separate collection
and land disposal of
food processing
wastewater4
HI. Site contralnts;
secondary treat-
ment method
ODx
Biological secondary treatment:
primary sedimentation, activated
sludge, disinfection, ocean
disposal
n/a
od2
Biological secondary treatment:
primary sedimentation, trickling
filtration, disinfection, ocean
disposal'
n/a
ODj
Physical-chemical secondary
treatment: chemical primary
treatment, filtration, activated
earbon adsorption, disinfection,
ocean disposal'
n/a
IV. Alternative sites
od4
Relocation of all or portion of
facilitie s
r./a
V. Agricultural or land-
scape Irrigation,
separation of waste
streams
OD/RZ!
Secondary treatment11, disinfec-
tion, ocean disposal*
Secondary treatment
at Scons Valley,
disinfection, land-
scape irrigation with
excess transported
to SC outfall
OD/R£2
Same as OD/REj for City of
Santa Cruz wastewater
Separate treatment of
East Cliff, Capitola,
Aptos and La Selva
wastewater at SC
site, agricultural
irrigation with effluent,
excess to SC outfall
OD/REj
Same as OD/REj plus agricultural
irrigation with a portion of effluent
Separate treatment of
tannery waste, transport
to SC outfall
2 92
-------
Alternative
Summary system description
Issue
number4
Santa Cruz wastewater15
Other wastewater
VI. Local agricultural
irrigation In
secondary reclama-
tion area*
OD/RI.
4
Same as ODj plus a portion of
effluent treated with coagulation,
clarification, filtration3, and
distribution to permit unrestricted
Irrigation use.
n/a
VII. Pajaro Valley
groundwater
overdraft1
OD/REj
Same as ODj plus a portion treated
for phosphorus removal, filtration,
disinfection, transport, storage
and distribution in the Pajaro
Valley for unrestricted irrigation
Watsonville: see
text
OD/RE6
Same as 00. plus a portion trans-
ported and distributed in Pajarc
Valley for less sensitive crops
Wat3onviller see
text
od/re7
Same as OD^
Watsonville: treat-
ment of secondary
effluent for phosphorus
removal, filtration,
activated carbon
adsorption, ground-
water injection
VIII. Stream flow
augmentation:
San Lorenzo
River1
OD/RSg
Same as 0D/R2, or OD/REj,
plus a portion discharged to
the San Lorenzo River
Watsonville: see
text
IX. Sludge disposal1
od5
Same as OD. except solids
disposal by algestion, dewaterlng
and landfill disposal
n/a
0D6
Same as OD, except solids
disposal by lime stabilization,
mechanical dewaterlng and
landfill disposal
n/a
X. No project
NPi
No changes to existing system
n/a
aK»'/
LD • Land disposal project
RE - Reclamation protect
OD - Ocean disposal project
SC • Santa Cruz
''includes all westewate-s in the wastewater facilities planning area except where listed under "other
wastewater" or modified in a footnote. Note that Watsonville wastewater is not Included In SC wastewater
under any circumstances.
cUntll 'ssue 'II secondary treatment is assumed to consist of primary sedimentation, activated sludge,
and disinfection with sludge processing by digestion, lagooning and land disposal.
tfFor the purpose of developing Table I beyond Issue I, it is a.sumed that Issue I analysis Indicates CD
Is most Wable. Otherwise the alternatives will oe.extended from REi or LDj.
•john inglls frozen Foods and Pacific Coast Producers.
'Solids disposal assumed to be by digestion, lagooning and land disposal until Issue IX Is resolved.
'Solids disposal assumed to be by lime stabilization, mechanical dewaterlng and disposal In a
landfill until Issue K Is resolved.
Type of secondary treatment dependent on Issue III: assumed for purpose of taole development to
be activated sludge until Issue III 1« resolved.
'Mineral Quality of SC effluent must be upgraded by stream separation when used for Irrigation as In
Issue V.
J joint disposal of municipal and selld wastes considered under Task D3.
293
-------
SELECTED ENVIRONMENTAL IMPACTS
Project Alternatives
selected type* or
impact
<*1
00/
">1
°°1
°02
°°j
00
4A
OD«
"l
00/
rei
00/
%
00/
00/
M3A
00/
**38
00/
re4A
00/
ft£
4B
00/
00/
00/
RE,
°°5A
""sB
°°6A
°D6B
NO
action
Marine
Alteration of benthic
community
L*
L
L
L
L
L
L
L*
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
Bioaecumulation of
heavy metals, pes-
ticide*, etc.
L
L
L
a
L
L
S*
L
L
L
L
L
L
L
L
L
L
L
»,
L
L
L
Habitat changes
L
L
L
L
L
L
L
L*
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
Beach erosion/lit-
toral sand trans-
port
N*
L
L
L
L
L
I
N*
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
Public health (shell-
fish/recreation)
L
L
I
L
L
L
L
L
L
L
L
L
L
L
L
I
L
L
L
L
S
Aesthetics
L
L
L
L
L
L
L
L4
L
L
L
V
L
L
L
L
L
L
L
L
L
L
S
Terrestrial
Soils/crops (salts*
heavy metals)
N
N
N
It
N
N
N
M
N
I
L
L
l.
L
L
L
N
N
L
L
L
L
Jf
Plant yields
N
N
N
H
M
N
N
M
N
S
S
S
S
S
N
S
S
S
N
N
N
N
N
Crop marketability
N
N
N
N
N
N
N
N
H
N
H
M
M
N
M
M
H
N
H
M
N
N
N
Odors
S
S
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
S
Groundwater contamin-
ation (virus.
bacteria)
S
$
N
N
N
V
N
P
P
P
P
P
P
P
P
P
P
P
L
L
S
5
N
Veoetation, fish and
wildlife
s
s
H
H
K
N
N
M
S
M
M
M
M
M
*
M
M
I
L
L
L
L
L
Hi storical/archeolog-
ical
p
p
P
P
P
P
P
P
P
P
P
P
P
P
9
P
P
P
P
P
P
P
P
Public health (dis-
posal area vicin-
ity
s
s
N
#
s
H
N
S
L
S
S
S
S
S
S
S
S
N
S
S
S
S
N
Land uses
M
s
N
H
N
N
S
M
L
s
s
s
s
s
L
S
S
i
L
L
L
L
L
Solid wastes (sludges
M
S
M
M
n
M
M
M
M
M
M
M
M
M
M
M
H
M
M
M
M
M
M
Energy consumption
S
L
L
L
L
L
L
M
L
L
L-S
L-S
S
L
L
S
L
L
L
L
L
L
L
Capital costs
M
s
S
S
S
S
S
M
S-M
S-M
S-M
M
S
S
M
a
S
N
Operational costs
S
L
L
L
M
L
L
M
L
L
S
S
L-S
L
S
L
L
L
*The impacts in this case result from e cessation of effluent discharge
into the ocean.
^Growth impacts vere under investigation during initial alternative
fonsulation stage. These impacts are, in part, dependent upon Ad-
ditional air quality and land use planning information. Alternatives
which include reclamation offer a potential for res»ving Jisited
water supply as a growth constraint.
Potential lapacts
H MAJOR - highly significant. Distinct impacts such as loss of,
or considerable Modification of, maber, amount or use of a
resource.
S SUBSTANTIAL * clearly measurable and discernible. No question
of changes.
P PROBLEMATICAL - uncertain; not necessarily predictable. Changes
My be hi^ly tignificant but not clearly definable or observable,
and eenerally an extensive eonitoring operation would be needed to
determine impact. if any. Changes may be greatly conditioned by
outside variables. May usually be determined only throuqh ex-
haustive observations and/cr research. Certain potential impacts
related to public health, aesthetics, crop marketability, land
use, etc., »ay be included under the heading of "problematical"
rather than slow.* These represent "psychological" impacts which
¦ay substantially affect areas such as land use. This ''worry
factor" tends to increase in areas where information is scarce or
lacking, and usually decreases correspondingly as information is
developed.
N NOME - no observable or measurable impacts.
L tOW - discernible changes, although not necessarily easily
measurable or easily defined.
-------
D.M.CALOWEU.PE
T.VLUTGEPE pr»«.e*^
L. •. DUNOP. PE r«»c Vie* Pr»»
L A. FREE MAN. P£ Vtc* Pr*»
4. L. STUAGEa* V.c* Pf#t
L. N. HOAG.PE Cin:io'
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J A. COTTER Al. PJ
e. s. ooasov pi
D S PARKE* PE
W. H. U«TE. PS
F460S
Santa Cruz Wastewater Facilities Planning Study
To: Board of Control/lnteragertcy Advisory Committee
(See Distribution List)
From: Robert L. Mills
Subject: SCREENING OF INITIAL ALTERNATIVES
INTRODUCTION
Based on the Strategy for Alternative Formulation, nineteen wastewater and four
sludge alternatives were developed through consideration of key issues. Fifteen
of the wastewater alternatives included all Santa Cruz flows, while four wastewater
alternatives looked specifically at Scotts Valley, Watsonville, or the Santa Cruz
food processors. These alternatives were presented at Board of Control meetings
on June 8 and July 20, 1977, and at a public workshop on August 10, 1977. Based
on recommendations of the consultants, the Board of Control, at their meeting on
August 17, 1977, adopted five final alternatives for more detailed evaluation. The
following are the final alternatives:
ODj Activated sludge treatment at Neary's Lagoon and ocean disposal,
including an evaluation of air versus pure oxygen activated sludge
treatment processes.
OD43 Abandonment of Neary's Lagoon treatment plant and construction of
a new air activated sludge plant west of town; includes ocean
disposal.
OD/RE5 Activated sludge treatment at Neary's Lagoon with advanced waste
treatment and seasonal reclamation of Santa Cruz effluent in Pajaro
Valley for unrestricted agricultural irrigation. . Consideration will
also be given to reclaiming Watsonville effluent under this alternative.
BROWN AND CALDWELL
CONSULTING ENGINEERS
August 22, 1977
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295
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Screening of Initial Alternatives
Page Two
OD/RE7 Advanced waste treatment and reclamation of Watsonville effluent
for a salt water intrusion barrier at the mouth of the Pajaro River
combined with OD^ or OD43.
OD7 Advanced primary treatment and ocean disposal at. Neary's Lagoon
as established mU. S. Senate Bill 1952. '
; OD- is presently an illegal alternative. The Board of Control decided to evaluate •
' it further because of the possibility of a change in Public Law 92-500 to make it
: legal. The Board of Control felt that if the alternative is not evaluated at this
, time and the law is subsequently changed, there would be additional project
. delays and increased study costs while alternative OD7 was being evaluated,
i The Environmental Protection Agency cannot consider an illegal alternative and
- has directed Jones & Stokes Associates, Inc. the environmental impact statement ;
1 consultant, not to consider OD7. An attempt will be made to resolve this problem. =
; with EPA as soon as possible. Brown and Caldwell, the facilities planning con- ;
; sultant, will evaluate OD7 last. Because of the legal issue, all comments on
OD7 are highlighted.
A basic criterion for selecting final alternatives was the need to limit them to a
small enough number to permit detailed consideration of each alternative and not
dilute the analysis. As a guide, our contractual requirement of two to five
alternatives was adopted because this range corresponded to the budget available
to do the work. The SWRCB's guidelines (January, 1975) also support this
concept as follows:
"The objective of the screening process is to reduce the number of
alternatives to just a few (two to five) of the more viable ones so
that a very thorough analysis of each can be made ... In no case
should less than two alternatives be selected for detailed analysis
and in most cases, the number selected should exceed five or six."
Another criterion was to develop a list of viable alternatives that were representative
of the types of engineering problems and systems of interest. These were:
1. Siting considerations. Comparison of Neary's Lagoon to other
treatment plant sites.
2. Treatment considerations. Comparisons of conventional secondary
treatment to possibly less costly and less space-consuming
marine secondary (or advanced primary treatment).
BROWN ANO CALDWELL 1501 NORTH BROADWAY WALNUT CREEK, CA 94596 (415) 937-9010
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296
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Screening of Initial Alternatives
Page Three
3. Regional reclamation systems involving intracounty transfers of
reclaimed water.
4. Local reclamation systems involving less transport costs with
users close to the source of water.
Alternatives ODj, OD^g, and OD7 allow comparisons for items (1) and (2) above,
while OD/RE5 and OD/RE7 allow consideration of items (3) and (4) above. A
minimum of five alternatives is necessary for consideration of all four items, which
permits no redundancy in alternatives.
BASIS FOR REJECTION OF ALTERNATIVES
The reasons for eliminating the other alternatives are presented below.3
LDt (Total land disposal of secondary effluent)
1. It was the most expensive alternative ($130 million in present
worth costs).
2. It required 6,900 acres of land. This much unused, flat land is
unavailable near Santa Cruz. Adoption of the alternative would
have significant land use impacts.
3. It is energy intensive (51 million kilowatt hours per.year).
OD/LDi (Land disposal for food processors)
This is a special alternative to determine whether or not it would be less
costly for the food processors to participate in a municipal system. Results
of this analysis will be incorporated in the evaluation of the final alternatives.
OD2 (Trickling filters and ocean disposal)
1. It is esthetically less acceptable than ODj. Odors are more difficult
to control. Stacking the trickling filters on top of the secondary
sedimentation tanks to save space results in a 50 ft tall structure
that would create visual impacts.
aJones and Stokes' environmental impact ranking prepared for the public workshop
was also considered in this process.
BROWN AND CALDWELL 1S01 NORTH BROADWAY WALNUT CREEK. CA 94596 (415) 937-6010
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297
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Screening of Initial Alternatives Page Four
OP2 (continued)
2. The performance of trickling filters is more difficult to generalize
than for activated sludge. In some cases, effluent solids are higher
and in other cases, lower than for the activated sludge process.
There is little experience to draw from for wastewater and performance
requirements of Santa Cruz; therefore, a pilot study would be required.
A pilot study would delay construction. Also, the need for an addi-
tional SWRCB review step would delay construction. Such delays
would not be acceptable to the regional board.
3. At the present state of knowledge, it should be noted that the loading
criteria adopted for the trickling filter and secondary sedimentation
tanks are tentative. Costs should properly be expressed as a range
reflecting this higher uncertainty relative to the activated sludge
process. For instance, chemical addition might be necessary to
enhance secondary solids settleability. If chemicals were added,
the cost of OD2 would likely be above ODj, rather than lower as
previously indicated.
OD3 (Physical/chemical treatment and ocean disposal)
1. It is an expensive alternative ($90 million in present worth costs).
Much of the cost is for operations and maintenance which are not
grant fundable and must be paid entirely by the local agencies.
2. It is extremely energy intensive (16 million kilowatt hours per year).
3. The furnace used to regenerate activated carbon may impact air
quality.
OD4A (Activated sludge on Southern Pacific property and ocean disposal)
1. It may conflict with other possible uses of the Southern Pacific property,
such as low-income housing.
2. It tends to surround Neary's Lagoon and the park with treatment
plants.
3. It was attractive when the possibility existed for concurrent use as
a solid waste front-end plant. Such a dual use was found to be
infeasible because insufficient space was available.
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298
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Screening of Initial Alternatives
Page Five
OD4A (continued)
4. Use of the land could be reconsidered further if ODj is adopted
as the final alternative (input from the Santa Cruz General Plan
Review Committee and other agencies would be sought).
RE2 (Advanced waste treatment and total reclamation)
1. It was the second most expensive alternative ($124 million in
present worth costs). Much of the cost is for operations and
maintenance and must be paid by local agencies.
2. It has no outfall and therefore lacks flexibility. If something goes
wrong with industrial source control, there is no place to put the
effluent without contaminating the reclaimed water reservoir.
3. It reclaims 18,000 acre-ft of water per year. The task C6 draft
report states that demand exceeds the existing supply in the
Pajaro Valley by 16,000 acre-ft per year in 1999. Relative to
other alternatives, this one would produce more water than is
required to satisfy the overdraft.
4. Harkins Slough is the only apparent possible site for the 13,000
acre-ft treated water storage reservoir, but the fluctuating water
level would impact a valuable fish, wildlife and riparian resource,
and there are Indian mounds in the area which might be inundated.
OD/RE2A OD/RE2B (Seasonal reclamation of East Cliff, Capitola and Aptos
effluent in the Pataro Valley)
1. It is not as attractive as OD/RE5 because only 5,000 acre-ft per
year is reclaimed (as opposed to 10,000 acre-ft per year for
OD/RE5) and the unit cost of reclaimed water is therefore higher.
2. Since it requires two separate secondary treatment plants side by
side, it requires more land at Neary's Lagoon.
3. Parallel treatment plants imposes more operational complexity.
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Screening of Initial Alternatives Page Six
QD/RE3A and OD/RE3B (Separation of tannery and seasonal reclamation of remaining
effluent in Pajaro Valley)
1. Ocean disposal of tannery wastewater alone may result in
noncompliance with ocean plan requirements due to the absence
of dilution with municipal effluent and lack of good initial
dilution in the outfall.
OD/RE4A (Treatment plant relocation and seasonal reclamation on north coast)
1. Agricultural irrigation is only 5,000 acre-ft per year in this area.
2. This alternative is dependent on relocating the plant to the west
site.
3. There apparently is no extreme water shortage in this area. Thus,
the unit cost for reclaimed water is much higher than alternative
sources , such as wells.
4. Most of the other alternatives could be flexibly designed to permit
future use of reclaimed water in the area. The USGS is planning
a groundwater study of the area which should aid in defining any
groundwater or surface water shortages and permit reconsideration
of this alternative in the future.
OD/RE43 (Local landscape and golf course irrigation from Neary's Lagoon)
1. The demand is only 150 acre-ft per year, thus the unit cost of
reclaimed water is very high.
2. These markets might be better served by an extension of the Scotts
Valley wastewater reclamation system to make use of the available
hydraulic head rather than pumping water from Neary's Lagoon.
The mineral quality of the Scotts Valley effluent is also superior
to that of Santa Cruz, making it a more attractive supply.
OD/REg (Seasonal reclamation of Watsonville effluent for irrigation of orchards)
1. If fruit continues to be harvested from the ground, there would be
potential health concerns. Treatment at the tertiary level would
be required to overcome these concerns, making this alternative
less competitive economically.
BROWN AND CALDWELL 1501 NORTH BROADWAY WALNUT CREEK, CA 94596 (415) 937-9010
ENVIRONMENTAL SCIENCE AND ENGINEERING
WALNUT CREEK PASAOENA EUGENE SEATTLE TUC3CN
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Screening of Initial Alternatives
Page Seven
OD/RE0 (continued)
2. There is no existing institution set up to sell the effluent to
farmers. This is also a drawback to OD/RE5 but not OD/RE7.
3. Salt content of Watsonville effluent is high and may be unacceptable
to farmers.
4. Since the orchards are not in the area of depressed groundwater
levels and saltwater intrusion, there is less expensive irrigation
water available.
5. A more direct and effective way to satisfy the overdraft situation
would be to provide effluent to the drawdown area either through
irrigation (OD/RE5) and by a "barrier" (OD/RE7).
BASIS FOR ACCEPTANCE OF ALTERNATIVES
Reasons for selecting the chosen alternatives are as follows:
ODi* (Activated sludge treatment at Neary's lagoon)
1. Follows original city plan to use Neary's lagoon site as an interim
park and lagoon site with ultimate use for wastewater disposal.
2. It is the least cost alternative complying with federal secondary
treatment requirements (see comments on OD2).
OD4B (Activated sludge treatment on western site)
1. Removes treatment plant from Neary's Lagoon and the downtown
area. An architecturally treated raw sewage pumping station would
have minimal impact. Retains aind enhances full value of park and
wildlife refuge.
2. Compatible with solid waste processing alternatives should they
ever be implemented.
3. It is located at a site that is presently designated for industry rather
than for homes or commercial purposes in the existing City of Santa
Cruz General Plan.
BROWN AND CALDWELL 1501 NORTH BROADWAY WALNUT CREEK. CA 94596 (415) 937-9010
ENVIRONMENTAL SCIENCE AND ENGINEERING WALNUT CREEK PASADENA EU3ENE SEATTLE TUCSON
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Screening of Initial Alternatives Page Eight
OD7 (Marine secondary at Neary's Lagoon)
1. Impacts on Neary*s Lagoon should be no more than at present
(at least until 1999 with modest impacts thereafter).
2. Potentially the most cost-effective alternative for waste disposal,
should the law change to make it legal!
3. Consideration should be given to it now, rather than later, as it
might be eliminated for technical reasons rather than legal reasons.
Not studying it might leave an unevaluated "strawman" that -would
cast a shadow on the conclusions of the study and affect the
Lmplementability and acceptability of the recommended project.
OD/RE5 (Activated sludge treatment at Neary's Lagoon, ocean disposal with
seasonal tertiary treatment and irrigation reuse in the Pajaro Valley)
1. It is representative of a series of reclamation alternatives that
involve intracounty transfers of water (OD/RE2A/ OD/RE2B/ OD/RE3A,
OD/RE3B, OD/RE5).
2. It will produce 13,400 acre-ft of water per year in 1999, which is
commensurate with the 16,000 acre-ft of overdraft in 1999 as determined
in task C6. (The incorporation of Watsonville effluent on the project
could be used to balance the demand.)
3. It has no significant impacts on Harkins Slough as does REj.
4. It is more flexible than REj in that it incorporates an outfall for
Santa Cruz for blowdown of "off spec" water.
OD/RE7 (Advanced treatment for Watsonville for salt water intrusion barrier)
1. High potential for positive impact on groundwater yields.
2. Economics and technical feasibility very dependent on a pilot study;
however, timing of pilot studies would not conflict with permit
compliance schedules because outfalls will be required for both
Watsonville and Santa Cruz.
BROWN AND CALDWELL 1501 NORTH BROADWAY WALNUT CREEK. CA 94596 (415) 937-9010
ENVIRONMENTAL SCiEKCE AND ENGINEERING WALNUT CREEK PASAPENA EUGENE SEATTLE 7l;CS0N
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Screening of Initial Alternatives
Page Nine
OD/RE7 (continued)
3. Cost-effectiveness would be enhanced if it were shown that
additional groundwater yield due to the project was greater than
that assumed.
SLUDGE DISPOSAL
Based on the results of the analysis of the sludge processing alternatives, ODg^
was adopted over OD5B/ OD6A anc* 0^6B* OD5A consists of anaerobic digestion,
mechanical dewatering, and trucking to landfill for all the final alternatives.
This process is less expensive and uses less energy than OD6a> which consists
of lime stabilization, mechanical dewatering, and landfilling. OD53 and ODgg
were eliminated when OD2 was eliminated since they consider processing trickling
filter sludge. The adoption of this method of disposal is also enforced by the
conclusions of task D3, where the preliminary determination is that a combined
sludge/solid waste resource recovery project is not cost competitive with the
continuation of landfill disposal. This latter conclusion is currently being reviewed
by city and county staff.
Distribution
R. Bain, Jr., Brown and Caldweu
P. Baldwin, Supervisor
J. Cooper, Director of Public Works, City of Watsonville (alt.)
W, Fieberling, Director of Public Works, City of Santa Cruz
R. Jones, Jones & Stokes Associates, Inc.
M. Liddicoat, Supervisor
C. Melville, Council Member, City of Santa Cruz
H. Nelson, County Sanitation District
C. Palmtag, Council Member, City of Watsonville
G. Patton, Supervisor
D. Porath, District Engineer, County Sanitation District
L. Butler, Jr., State Solid Waste Mangement Board
W. Doyle, UCSC Coastal Marine Studies
J. Goni, Regional Water Quality Control Board
S. Hansch, Central Coastal Commission
W. Helphingstine, Environmental Protection Agency
M. Jacobs, Santa Cruz County Planning Department
R. Johansen, Santa Cruz County Watershed Management
J. Liebster, Association of Monterey Bay Area Governments
J. Nighswonger, Regional Water Quality Control Board
BROWN AND CALDWELL 1501 NORTH BROADWAY WALNUT CREEK. CA 94596 (41S) 937-9010
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