Various federal and state agencies have commented officially on the Cambria Community Services District March 4 notice that RBF Consulting is preparing the environmental impact report on the emergency water supply project, along with a 15-page project information packet.
District General Manager Jerry Gruber told CCSD directors April 23 that the consultant had received about 80 comment letters on the project, totaling more than 300 pages.
The district’s notice packet lists issues to be evaluated through the environmental impact report (EIR).
What makes this situation different from the norm is that an EIR usually is prepared before a project is built so agencies that have to sign off on the plan can identify potential problems during the design phase, before the project is built.
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The CCSD plant, however, was constructed last year under a drought-triggered emergency permit issued by the county.
The plant has just concluded a three-month operational test period.
Those with concerns essentially are commenting after the fact, seeking modifications to what is already there.
Some issues had been officially addressed March 2 in a notice of violations from the Central Coast Regional Water Quality Control Board.
The EIR is a crucial part of applying for a permanent permit to operate the plant during future emergencies, because it estimates how the plant could affect its surroundings and the environment. Agencies then comment on those estimates.
The current process is the predecessor to the formal EIR procedure, because the EIR is not yet complete. This set of comments will help guide any adjustments to the plan, and the plan itself, before the EIR goes into the next stages, its draft and then final form.
Among the agencies commenting in this round to Rita Garcia, RBF Consulting’s technical manager, were National Marine Fisheries Service/National Oceanic and Atmospheric Administration (three pages), California Coastal Commission (12 pages), state Department of Fish and Wildlife (nine pages), U.S. Fish and Wildlife Service (three pages) and California State Parks (10 pages).
Some agencies expressed general concerns, others very specific ones, and still others a mixture of both. Many of the stated concerns were for impacts to federally listed and other species, such as steelhead; impacts to groundwater and the aquifer; impacts on humans; discrepancies in mapped boundaries of the project site; and effects on San Simeon Creek and its lagoon.
But perhaps the greatest concern for most of the commenting agencies is the emergency water supply project’s final phase — an evaporation basin or pond designed to hold a couple of years’ worth of the plant’s discharge or brine so most of it can evaporate into the atmosphere.
Mechanical evaporator blowers spray the brine in mist form over the basin to hasten that evaporation process.
Collectively, among the agency comments about the pond are concerns about its limited capacity, location so close to a state park campground and other areas of concern, noise, glare from the reflection of the stored brine, mist that reportedly spreads beyond the pond’s boundaries and dangers to migratory birds, red-legged frogs and other species.