CCNM: Los Osos Views

Sullivan brief

2007-04-28T14:04:00.000-07:00

ON SITE NITROGEN SEQUESTERING INSTALLED AND FINALED

2006-12-20T11:14:00.000-08:00

Questions and answers about the final installation:

What have you done on your property to reduce nitrogen from going into the groundwater?

My name is Steven Paige, I own a home on a 25 by 125 foot lot in the prohibition zone. I submitted plans for to reduce nitrogen emissions by 60 to 80 percent from my septic outfall with the County on May 11, 2006 after receiving approval from Harvey Packard. The project was completed and received final inspection by the County on October 23, 2006 and is now in operation.

How does your system work?

My system is very simple. I have two toilets side by side. One is a bidet used for urine only. The other is a toilet used for solids. The urine only bidet faucet is spring loaded and washes the dry bidet bowl with about 1/3 cup per washout. All the urine goes into a parallel holding tank that is pumped and removed from the water basin once or twice a year. One truck can haul a years supply from twenty to fifty households.

How do you verify how much nitrogen is removed?

A C-42 licensed hauler fills a test container and the container is sent to a testing lab and tested for total nitrogen. That small amount is multiplied by the volume removed from the holding tank. The sequestered nitrogen content is subtracted from the assumed EPA output from a normal two person household giving you the percent reduction in contamination.

What does it cost to operate the system?

The total output with flushing water is about 200 gallons a year for two people and the estimated cost for hauling is about $150.00 per year. The system cost less than $1500.00 to install. I also save on my water bill by about 1/5 because of my reduced flushing volume from the bidet. The small square tank in the picture holds access to the Liquid waste tank.

What if you sell your house?

I have a deed restriction for waste nitrogen sequestering recorded with the County that would show up on the title report. Attached to it is exhibit one, a "Nitrogen Sequestering Homeowner's Manual" that would also show up in the title report.

How well is the system expected to work?

Using accepted EPA data, Standardized Medical data on nitrogen in urine and empirical mathematics it can be determined that sequestering is equal to or better than the Nitrogen reduction assumed and permitted for the TRI-W sewer project of 7 ml/l remaining in the balance of septic waste.

How did you come up with the idea?

It is a well researched idea originating in Sweden. Swedish studies are geared toward using human liquid waste after deodorizing and disinfection as commercial nitrogen fertilizer because making standard Nitrogen fertilizer is very energy intensive. Eighty percent of the cost for Nitrogen fertilizer is related to the cost of Natural Gas used to make it. The Swedish see urine as a desirable future resource much like any other recyclable.

How would you apply your situation to the CDO process?

I would allow Urine sequestering to be used as a carrot to avoid the CDO process. I would use the once or twice a year pumping tickets and Lab results as verification. I myself asked for a waiver when I submitted my plans for review 5 months ago. I will push soon for another option.

Would you expect this to affect the zero discharge enforcement on your property?

Yes I believe it will. If you encourage people like myself that want to meet much higher standards for their on site waste disposal you get immediate positive temporary remediation of the Nitrogen problem. I would encourage this with a proportional discharge order instead of a zero discharge order for small lots compared to one acre parcels that are approved to discharge as per the basin plan.

A Proportional discharge order would mean that a 50 by 100 foot lot would be allowed 16% to 25% of the pollutant discharge for an acre. As a member of LOCAC land use committee I have seen contemporary one acre approvals include houses with many homes approved on one acre. With one acre as the standard, smaller lots should be allowed a proportional discharge.

An additional settlement agreement for proportional discharge and Urine sequestering would encourage water conservation. People not wanting to jeopardize the value of their property would install a system like mine that any plumber could install. To meet the requirements of the settlement they would have to practice careful water conservation and sequester, pump, and haul urine outside the basin. The agreement would have them hook up to the sewer when available but still be allowed to sequester and discharge if problems arose with the time line construction.

The water board would benefit by having the nitrogen removed immediately. They also would optimize air pollution compared to pumping whole tanks. Sequestering would reduce conformance air pollution by 95% thus avoiding "parallel standards" challanges for CEQA exemptions in air quality aginst the RWQCB. Sequestering/conservation would eliminate Prop 218 benefit challenges that on site secondary treatment may raise if allowed. The solution is a front end solution that would go away when the sewer is hooked up to the house.

Intensive water conservation of this order would require:

Micro flush 1/3 cup urine flushing in the bidet or European dual flush toilets.
Second generation HE washing machines.
Zeroscape landscaping.
Ultra low flow shower heads.
Ultra efficent dishwashers.
Removal of garbage disposals for another 15% Nitrogen reductions (85% total).
Careful use of water.

With a proportional discharge order from the RWQCB you not only encourage a more usable and efficient sewer system within Prop 218 law but you also jump start smart growth temporary solutions that are married to the future solution of basin groundwater overdraft. Behavior modification is the most efficent method of compliance in the short term.

APPROVED

2006-05-21T17:17:00.000-07:00

Liquid human waste sequestering has been approved.

A special thanks to the following people:

APPROVED- Harvey Packard-RWQCB

APPROVED- BarryTolle-County Building and Planning

APPROVED-Laurie Salo-County Public Health

Permit is in hand.

Urine Separation Pumping Alternative- Letter to RWQCB- Design Plan for Property

2006-04-04T12:13:00.000-07:00

Lori Okun and Philip G. Wyels
Senior Staff Counsel and Assistant Chief Counsel
State Water Resources Control Board
Office of Chief Counsel

RE: Steven Paige- Comments for April 28, 2006, Central Coast RWQCB Hearing

Dear Honorable Board Members and Council,
I have made a voluntary proposal to cut the Nitrogen emissions on my property by 58%. On March 23 I turned over to your office an alternative measure to septic pumping. The site plan and validation of the design are attached to this letter. It follows the logic of the approved order for segregation and transfer of Nitrogen laden waste from the septic tanks. Septic pumping by your estimation will reduce Total Nitrogen by 22%.
The solution I propose is a copy of a well studied Swedish solution to ‘smart pump’ source separate urine waste by behavior modification. You install a urine only toilet (Bidet) and isolated storage tank, then pump the segregated contents causing the following positive effects:

1) It prevents the unprecedented withdrawal from the water basin of 22 to36 Million Gallons a year caused by septic pumping if required Community wide.

2) It cuts Estuary Airshed NOx to Water Borne Nitrogen emissions from diesel truck effluvium hauling by 90% by reducing the hauled liquid volume.

3) Using EPA data, it reduces Total Nitrogen from the waste stream by 58% compared to 22% described in your pumping order.

4) It cost me 1/10 the amount of money per year for compliance.

5) With the additional removal of my garbage disposal, it would allow immediate improvement of waste discharge for Nitrogen in an order of magnitude that matches your approved waste discharge permit for the Broderson reclamation leachfields. The resultant Nitrogen release from the balance of my septic effluvium is approximately the same for my family as the amount allowed by your previous discharge permit but includes additional water conservation, not basin withdrawal.

My intension is to install the equipment so I can be given a section §13269 PCA Waiver by your office. I would expect a small processing fee to be appropriate based on my ability to pay. I think it would like you to consider an individual ‘Minor Violation Notice’ Section §13399 PCA because it is more fitting to the level of pollution. I’m not a major sewer plant or big industrial polluter. My methodology of Nitrate removal, because its environmental impact is less than yours, is my personal choice of compliance subject to § 13360 PCA:

“Manner of compliance

(a) No waste discharge requirement or other order of a regional board or the state board or decree of a court issued under this division shall specify the design, location, type of construction, or particular manner in which compliance may be had with that requirement, order, or decree, and the person so ordered shall be
permitted to comply with the order in any lawful manner.”

Myself and other residents with limited economic resources have reservations about the boards choice to issue a ‘zero’ discharge order after 2010 because one standard is allowed by the Los Osos Community Service District outlined in their discharge permit and another standard is imposed on homeowner’s to cease individual discharges after 2010.
If the LOCSD wastewater discharge permit meets federal standards that by law they had to, then the individual discharge standards of the People’s CDO’s exceeds federal standards and it’s cost to homeowners should be legally contested. The zero emission requirements are unnecessarily expensive and restrictive for homeowners.

Also, the dual standards clearly are inconsistent with Sec. 304 FEDERAL WATER POLLUTION CONTROL ACT encouraging sustainable, scaled, and economic water treatment. Simply put, the action eliminates altogether the use of sustainable, alternative, energy efficient, small scale waste treatment. Section ‘304’ encourages “promulgating” those systems as required and directed by Federal Law.

Further, With perceptions like the ones expressed in the Administrative Civil Liability Complaint No. R3-2005-0137 Pg. 430 lines 18,19,20 against the LOCSD where Chairman Young Stated:

“It's quite clear to me that the folks of Los Osos, in my opinion, are really not capable of addressing these issues with their wastewater disposal in a rational way.”

It’s hard not to assume that prejudice against small scale compliance led to the two different rulings being imposed. The zero emissions requirement conflicts with federal law directing States to ‘promulgate’ alternative systems and consider them as secondary treatment.

In a broader sense for all Californian’s, the ‘Zero’ emissions order also seems to be in conflict with extensive Federal studies encouraging sustainable on site solutions, small scale cluster systems, or community wide systems that use energy and economics as a critical path.

EPA smart growth policies and objectives of minimizing infrastructure while increasing urban population density cannot be consistent with the zero emissions requirement. If Porter Cologne enforcement is to have positive public participation, flexible ‘smart growth’ enforcement that uses a menu of solutions would give the PCA more ‘contemporary’ environmental creditability and quicker results. It is the only way we are going to get ‘smart growth’ density in Los Osos and still meet CEQA regulations and watershed criteria. Public participation is the key. So assuming the public are a bunch of idiots is THE real tragedy. Like myself, they are the key to the solution.

I think we have all suffered from the ‘cognitive dissonance’ of the Los Osos sewer issue, myself included. Tensions and misconceptions of Board members have made the CDO orders for individual home owners way out of the ordinary. Again, I think Minor Violation Notice’ Section §13399 PCA is a more appropriate to the level of pollution on my property and gives you more flexibility to encourage things like water conservation or integrate on site impervious drainage recharge (roof runoff) as a ‘blending requirement’ for septic tank outfall. Many older homes in Los Osos do not have on site drainage reclamation. Using kinder more flexible enforcement would give you immediate results and raise environmental awareness. Punitive pumping measures that withdraw 36 Million gallons of water from the basin without a CEQA study could be replaced with MVN’s and smarter effluvium management like I have suggested.

My second concern would be that the studies of the water contamination of the Morro Bay Estuary seem faulted. When a major pollution source has been entirely omitted from the Basin Plan and Morro Bay National Monitoring Program there is no possibility of scientific validity. That source is the Morro Bay Power Plant and the interrelationship of Air Shed NOx emissions and TN found in Bay waters.

Federal Studies of similar watersheds found in the sited references below disclose the fact that an average of 25% of the Power Plant NOx emissions return to the waters of Morro Bay. The recent License for the Duke Power NOx emissions allows 260 tons of NOx per year. If Federal studies are correct ,then for the last 50 years 25% of over 260 tons/yr (conservative estimate) or 3250 tons of Nitrogen has been recaptured into the Bay Hydrologic cycle from the Morro Bay Power Plant without having been included in Watershed planning and measurements. Any premise drawn from a plan without this Nitrogen input is without scientific merit.

Here are some simple math calculations that exemplify my concern:

For houeshold Nitrogen production:
If we compute the grams per household per day:
280 gal/Household X 3.78 L/gal X .007 g/L =
7.4 grams per household / day of TN allowed in the Broderson discharge permit.

Looking at the unstudied Power Plant Pollution:
260 tons (conservative) X 2200 lbs X 1/5000 Households X 1/365 per day =
0.31 lbs/day/household
From the referenced air shed studies below 25 % of
Air NOx returns to the Estuary so:
.31 lbs. X 25%( Air NOx to Waterborne N ratio) X 448 grams/lb =
34 Grams Total Nitrogen/day/household for forty years!

The allowed Nitrogen per household per day is 7.4 grams in the TRI-W Permit seems incidental to the allowed unstudied Power plant NOx to waterborne Nitrogen of 34 grams per household per day from the Power Plant Emissions. If these figures are even partly right, how could the Cease and Desist Orders be related to sound science. The Morro Bay Power Plant has been operating for 40 years and easily could be a major contributor to ground water TN in the aquifer. Its contribution has never been included in the Basin Plan. To substantiate my claim at a later time if need be I incorporate by reference all the following documents:

Alliance for the Chesapeake Bay. 1997. Air Pollution and the Chesapeake Bay. WhitePaper of the Alliance for the Chesapeake Bay. 16 pp
Boubel, R.W., D. L. Fox, D.B. Turner, and A.C. Stern. 1994. Fundamentals of Air Pollution.Academic Press: San Diego, CA.
Ecological Society of America. 1999. Acid Deposition: the Ecological Response. Paper presented at "Acid Rain Revisited: a Congressional Briefing Co-Sponsored by the Ecological Society of America and the Hubbard Brook Research Foundation."
Mason, R.P., W.F. Fitzgerald, and F.M.M. Morel. 1994. The Biogeochemical Cycling of Elemental Mercury: anthropogenic Influences. Geochim. et Cosmochim. Acta 58(15): 3191-3198.
Mason, R.P., N.M. Lawson and K.A. Sullivan. 1997a. Atmospheric deposition to the Chesapeake Bay Watershed--Regional and Local Sources. Atmospheric Environment 31(21):3531-3540.
Paerl, H.W. 1993. Emerging Role of Atmospheric Nitrogen Deposition in Coastal Eutrophication: Biogeochemical and Trophic Perspectives. Canadian Journal of Fisheries and Aquatic Sciences, 50:2254-2269.
Perry, J. and E. Vanderklein. 1996. Water Quality: Management of a Natural Resource. Blackwell Science, Inc: Cambridge, MA.
Puckett, L.J. 1994. Nonpoint and point sources of nitrogen i major watersheds of the United States. USGS Water Investigations Report 94-4001. U.S. Geological survey, Reston, Virginia.
Schlesinger, W.H. 1997. Biogeochemistry: An Analysis of Global Change, Academic Press, San Diego, CA.
Seitzinger, S.P. and R.W. Sanders. 1999. Atmospheric inputs of dissolved organic nitrogen stimulate estuarine bacteria and phytoplankton. Limnology and Oceanography 44: 721-730.
Shannon, J.D., and E.C. Voldner. 1995. Modeling Atmospheric Concentrations of Mercury and Deposition to the Great Lakes. Atmospheric Environment 29(14):1649-1661
US Environmental Protection Agency, Office of Air Quality Planning and Standards. 1997. Deposition of air pollutants to the Great Waters: Second Report to Congress. USEPA: Washington, DC.
US Environmental Protection Agency. 1997. Mercury Study Report to Congress. 181 pp.Vitousek, P.M., J. Aber, R.W. Howarth, G.E. Likens, P.A. Matson, D.W. Schindler, W.H. Schlesinger, and G.D. Tillman. 1997. Human Alteration of the Global Nitrogen Cycle: Causes and Consequences. Issues in Ecology, Number 1, Spring 1997. Ecological Society of America, 15 pp.

In considering my idea, I would like to also raise another issue. I am a disabled individual as determined by Court decree. I have an independent doctor’s analysis that states my earning capacity is reduced by 50% due to my disability. It seems that multiple CDO’s with one hearing are discriminatory against me and others in a like situation and violate the Federal Fair Housing Act.

Block or random CDO’s add up to discriminatory zoning actions against people with disabilities by a public agency. The CDO’s are applied to a zoned population of people, the prohibition zone, with no individual hearings. Public accommodation is limited to one hearing for all parties or blocks of parties in the prohibition zone. One size fits all.

The Federal Fair Housing Act makes it unlawful to utilize land use policies or actions that treat groups of persons with disabilities less favorably than groups of non-disabled persons. Blanket hearings and fines are discriminatory to disabled persons in public assisted housing, on assistance, group homes and persons receiving public assisted elder care because they cause economic hardship, traveling expenses and public facility accommodation hardships without consideration by your office. All these hardships are occurring PRIOR to enforcement hearings. It would be horrible to have the order put disabled people out on the street as an unintended consequence. Don’t you agree?

What I feel would constitute a reasonable accommodation for me would be a case-by-case review of myself and all property owners to be able to identify the personal needs of the handicapped or assisted income homeowners . Each disabled person, like me, living in Los Osos, should be entitled to a individual hearing by your RWQCB board if you use economically crippling CDO’s.

In my case of limited earning capacity, I have figured the cost of making the improvements on my property related to my assessed valuation. They exceed 0.5% of my property evaluation and hence I am requesting any information you may have about financial assistance per Section § 13291.5. PCA. My initial expense will be about $1800.00.

I think by me redefining a better ‘smart pumping’ solution and you redefining a more appropriate order (MVN’s) towards myself and others, we could mutually encourage immediate improvements in Los Osos water quality while conserving water, educating the public, and preserving air quality.

Steve Paige, Los Osos Ca.

Pumping Compliance Attachment to Plan Set

2006-03-26T03:59:00.000-08:00

Alternative Compliance Improvement Validation

Author: Steven Paige
Date: 3/21/2006
Property Location:
1554 Ninth Street, Los Osos, California
Owner of Record:
Steven Paige
Alternative System Designer:
Steven Paige
Installer:
Steven Paige, Owner/Installer Contractors License, Cl 385994

Subject to:

Alternative compliance to Order R3-2006 Central Coast Regional Quality Control Board INTERIM COMPLIANCE REQUIREMENTS set forth in paragraph B-3 "Other Methods" of Compliance.

As per the CRWQCB Staff report dated March 13, 2006 the benchmark reduction of nitrates was investigated by the RWQCB and a standard of 22 percent nitrate reduction was assumed by the six bi-monthly pumpings per year, per household (Pg. 2 Paragraph 2).

Project description:

This project describes an alternative storage, pumping, and disposal plan for a reduction of Water borne Nitrogen loading on the subject's property to reduce the loading by 22% or more on a yearly average.

Urine is proposed to be removed from the waste stream before entering the septic tank by direct source separation of the urine and feces utilizing human behavior as a separation mechanism. The urine is then stored separately and then pumped by a Septic hauling contractor to Santa Maria and disposed of at their sewer plant.

This project is based on the following assumptions:

1) Federal Data from the EPA ONSITE WASTEWATER TREATMENT SYSTEMS MANUAL EPA/625/ROO/008

2) The physical principal that matter cannot either be created or destroyed ad hoc.

3) Normal laws of mathematics i.e. multiplication and percentage calculations are the rule.

4) Data on TN (Total Nitrogen) differences between urine and feces where urine contains 75% TN and feces 25% TN¹²³ in the toilet waste stream.

5) Federal mandate in Section 503 of the Federal Clean Waters Act that Agency's 'promulgate' sustainable and alternative on site sewage disposal systems, that State Agencies are bound to be consistent with Federal Law, and that Federal law supersedes State law in this respect.

Project Design Standards:

1) Bidet installed is approved for disposal of liquid human byproducts and water as per ASME/ANSI Al12.19.2M Bidets have a 1 ½ inch drain and are considered .5 fixture units simplifying installation. Bidets can be plumbed out an exterior wall(See Plan).

2) ABS plumbing to UPC 2000 as adopted by the County of San Luis Obispo.

3) Waste Storage tank is non-corrosive meeting PCO standards for liquid corrosives and liquid fertilizer handling. Storage is in a portable above ground tank.

4) Septic tank improvements described meet NSF Section 46 testing and standards.

5) Charcoal filter, Float Alarm and Remote Alarm are NSF Section 46 compliant and approved.

6) Before final inspection there will be an initial Septic Tank Pumping and monitoring quarterly thereafter with re-pumping required after "sludge level is within eight inches of the outlet device" (as per RWQCB resolution 83-12). This is consistent with previous water board rulings.

7) The owner will verify with receipts the haulage of sequestered urine for verification by the RWQCB if desired. Haulage shall continue quarterly or as the alarm system so warns until the subject property complies with water quality standards equivalent to WASTE DISCHARGE/RECYCLED WATER REQUIREMENTS ORDER NO. R3-2002-0108 onsite or is connected to a community sewer approved by the RWQCB.

7) A deed restriction should contain all requirements and manuals as per this Alternative Plan so as to become part of a home sale title report if home is sold. The transferee will be disclosed in the disclosure report the nature and design of the system and it's operation, including human behavioral inputs. A copy of the restriction and manual should be necessary for final inspection.

Description of household pollutant reduction:

Urine containing 58% of the household nitrate production is separated from all other wastes unilaterally before going into the septic tank. 78% of TN comes from toilet wastes¹• 75% TN is held in urine content.¹²³ 78% X 75% = 58%. Also 58% > 22% therefore urine separation exceeds the criteria set by the RWQCB mandatory pumping program.

Removal of Garbage disposal will render the pollutant reduction further to 5% more reduction in TN, 28% reduction in BOD(5), and 37% reduction in solids⁵• Hence the total reduction is 63% reduction in TN, 28% reduction in BOD, and 37% reduction in solids entirely by behavioral source separation.

Source separation of trash products is an example of successful behavioral modification to augment sustainability and logic would assume that human waste source separation would have the same results. Persons not desiring to this option could continue with dictated pumping.

Offsite Airshed Pollutant Reduction

The estimated amount of waste haulage per household per year is 9000 gallons. 6 haulings x 5000 households x 120 roundtrip miles to Santa Maria (not including pump out pollution and idle time) = 3.6 Million diesel truck miles per year added to the San Luis Obispo Airshed.

NOx is produced by diesel truck effluvium shipping and is equal to 12.8 grm/mi⁶ X 3,600,000 miles X 1/2.8 grm/oz X 1/16 oz/lbs X 1/2200 Ibs/ton = 467 Tons of Atmospheric Nitrogen released. With 116 tons of Nitrogen settling out of the air and going back into the watershed!

Correct me if I am wrong here. What this really means is that for every pound of Nitrogen you are hauling you are dumping five pounds back into the Bay because there is only 78 grams of N per truck load and 384 grams are going into the Bay from the diesel exhaust. Contrarily, source separation cuts haulage per household by a factor of 400 gal/9000 gal. or 96% Then- 467 Tons X 4% = 18 Tons of NOx air pollution from hauling urine separate. That’s a big difference not even considering the traffic congestion.

Of the air NOx in the airshed it has been shown by the lengthily and encompassing study of Chesapeake Bay that 22 to 25 percent of the NOx returns to the watershed mechanically when air NOx is released in the adjacent area. My informational source for this claim is in : Atmospheric Deposition, A Handbook for Watershed Managers, Office of Wetlands, Oceans, and Watersheds U.S. Environmental Protection Agency Washington, DC 20460 EPA-453/R-01-009 September 2001 see:http://www.epa.gov/airtrends/nitrogen.html)
It is a fair assumption that the truck hauling NOx would follow on these percentages.

Salt Water Intrusion Reduction

For tank pumping the quantity of water removed from the hydrologic cycle of Estero Bay and removed from recharge is: 9000 Gallons/yr. X 5000 Households = 45 million gallons per year. The impact of this withdrawal is unknown but it is the equivalent of almost two months usage for the whole community. Source separation could avoid legal complaints by water purveyors for the huge draw against groundwater recharge.

Source separation including .2 liter urine wash down per flush for a family of three would probably not exceed 400 gallons per year. So 400 X 5000 households = 1.1 Million Gallons but the water conservation from saved toilet flushes 6 X 1.6 gal/flush x 365 days x 5000 households = 17.5 Million gallons/yr saved by not being withdrawn. The net gain to basin hydrology in any case would be over 15 Million gallons per year. There would be no net withdrawal.

The motivational feedback to not flush lots of water with urine is that pumping would occur less often costing the homeowner less money.

2% EPA Benchmark Affordability Reached7

The benchmark cost according to the EPA should not exceed 4% of yearly income of a family for both water and sewer cost. For sewer cost alone the amount would be 2%. The income of 33% of the families at Baywood Elementary earn below $28,000 per year with many being one income single parents like myself. $28,000 X 2% X 1/12 = $46.00/ MO. Or $138.00 per quarterly pumping compared to $800.00 for the tank pumping requirement. This would approximate the pumping cost of 100 gallons. Standard portable toilets cost approx $60.00 to service. Hence source separation would meet the low income community needs were Septic pumping does not.

Behavioral Motivation

Behavioral motivation is primarily monetary. The secondary motivation would be environmental awareness. Source separation could be eventually resource oriented where urine is reprocessed onto liquid fertilizer for agricultural users. Swedish studies involving resource source separation and contaminant removal are well documented and available from the author at the request of your department.

CONCLUSION

It is hoped by this permit application that both yourselves and the RWQCB will consider source separation and pumping as an alternative to septic pumping. It is understood that any approval for an alternative would have to meet the RWQCB needs if applied throughout the community. I think the plan for my property does that. This plan would make Los Osos cutting edge in resource management in line with advanced studies and pilot projects being carried out in Sweden and elsewhere without the risk of the project unknowns of using human urea as a resource. It sets up waste separation behaviors that are the most energy efficient way of processing human groundwater Nitrogen pollution (see enclosed study). Pending your approval, I have five other prohibition zone homeowners waiting for a similar installation.

The main reasons for approving my plan are:

1) 63% Nitrogen removal compared to 22%.

2) Lower cost per household.

3) No groundwater withdrawal, actually conserves groundwater.

4) Uses off the shelf industry standardized equipment.

5) Creates advanced environmental awareness.

6) 1/10 the traffic and air pollution generated.

7) Possible resource management in the future.

8) Much lower energy consumption requirements.

9) Economic advantage for many small local retrofitting contractors.

Thank you for your consideration. It is my intention to avoid a CDO on my property by making improvements immediately. Your prompt attention is necessary to prevent devaluation of my property and potential legal encumbrances caused by your inaction. Lets act now to save our Bay!

Steve Paige

1)Nutrients in urine: energetic aspects of removal and recovery M. Maurer*, P. Schwegler and T.A. Larsen EA WAG, Environmental Engineering, Uberlandstrasse 133, CH-8600 Dubendorf, Switzerland
2) Siegrist et al. et aI, 1976 2Beckerus et aI, 1998 3Jonsson et aI, 1997, Medcalf and Eddy, 2003
3) Department of Nutritional Sciences NS 160University of California, Berkeley Unit III: HUMAN PROTEIN NEEDS
4) 3 & 2 page 2.
5) Federal Data from the EPA ONSITE WASTEWATER TREATMENT SYSTEMS MANUAL EPA/625/ROO/008
6) http://www.epa.gov/air/airtrends/aqtrnd99/fr_table.html
7) EPA 832-B-97-004 Financial Capability Assessment

Source Separation Beats pumping by 100% for Denitrification at 1/10 the Cost and Energy.

2006-03-12T19:50:00.000-08:00

Could one answer be a new toilet that separates urine from wastewater streams? Here's an interm solution that could could become part of the finished design.

Separation reduces Nitrogen 55% from front end loading of your on site septic tank. If going to the bathroom in two different places would save you $2000.00 a year would you do it? It is energy smart to have you sepearate the two from the get go. Pilots studies are going on in Sweden, Mexico, U.K. and we need a solution fast! The water board has some justification in being frustrated. If we temporarily source seprate No. 1 and No. 2 till the sewer gets built then we have really improved the situation. Pumping alone was only going to remove 22%.

I did the bolding in the article so you could skim it if you're in a hurry.

Reprint Thanks To Enviormental Science and Tech. Mag.

Re-engineering the toilet for sustainable wastewater management.
May 1, 2001 / Volume 35 , Issue 9 / pp 192 A – 197 A.
TOVE A. LARSEN,
IRENE PETERS,
ALFREDO ALDER,
RIK EGGEN,
MAX MAURER,
AND JANE MUNCKE

"Municipal wastewater treatment needs rethinking. It is burdened with a pollutant load that it was never intended to manage."

Problems with the existing management system are manifold. The current system—waterborne transport and centralized treatment—consumes large amounts of fresh water. It discharges nutrients to water bodies, where they cause pollution and are lost for further use at a time when scarce raw materials are being depleted to produce synthetic mineral fertilizers. Concern is also growing about human excretion of micropollutants such as pharmaceuticals, synthetic and natural hormones, and their metabolites. Many of these substances (suspected to be largely excreted in urine) are not removed by biological wastewater treatment (1–3) and often are very potent, especially hormonally active agents, which have caused changes in the morphology and behavior of some species (4). Moreover, the spread of antibiotics to the environment could lead to increased resistance of microorganisms to these substances. Fortunately, a promising alternative to centralized wastewater management may soon be available that addresses many of these problems. It involves separation of urine from feces in a special “NoMix” toilet with in-house storage of the collected liquid followed by its subsequent transport and treatment (Figure 1). Such urine source separation is technologically easy to accomplish, and at pilot scale, the technology is already in place in several countries. At the Swiss Federal Institute for Environmental Science and Technology (EAWAG) in Dübendorf, the NOVAQUATIS project (www.novaquatis.eawag.ch) is exploring the engineering, microbiological, exotoxicological, economic, and social science aspects of this novel approach.

Source-separating urine provides a range of benefits. A urine-separating NoMix toilet saves 80% of the water used for toilet flushing, accounting for 30% of the average Western European’s direct daily water use and 10% of the total freshwater use in Switzerland. Because urine accounts for a large fraction of the wastewater nutrient load, this approach can also reduce emissions from fertilizer production and halt the contamination of agricultural soils by the heavy metals found in the raw materials used to produce synthetic fertilizers. It also reduces micropollutant discharges to water bodies.

Using existing collection and treatment infrastructure, urine source separation is well suited to aid the transition to decentralized wastewater management. For the approach to succeed, however, many stakeholders—consumers, public agencies, industry, and agriculture—must aid in the dissemination of NoMix technology.

Problem synthesis

Thousands of xenobiotic substances that have been brought into use in the past few decades are finding their way into municipal wastewater. Centralized treatment technology cannot deal with this new pollutant load and offers no incentive to polluters to seek better alternatives. Current urban water management practice contains strong elements of what economists call a natural monopoly, in which a single supplier can service the market at lower cost than two or more suppliers. This situation stifles innovation and locks in a technology that is inferior in many respects.

Therefore, municipal wastewater treatment systems should be moving toward source separation schemes, but it is not clear how to make this happen. What are the right technologies? How can they be implemented? Addressing the latter question may be the more challenging issue because of the current system’s built-in inertia—it is well established, long-lived, seems to adequately serve public needs, and has large amounts of capital invested in the present infrastructure, in which several complementary technologies work together to make the system function.

It may be feasible to unbundle wastewater management and introduce competition in treatment, for example, but it is hard to see how this can be done for transport. The sewer system is too extensive to sustain several independent providers. In fact, for most deregulated public utilities—power, rail transport, and water supply—network operation has remained a monopoly, and establishing competition in unbundled services has proven harder to accomplish than anticipated. Ultimately, household on-site technology would make today’s centralized wastewater collection and treatment infrastructure redundant. Important issues to be addressed include how the transition to a decentralized technology regime can be accomplished, what it would cost, and who is going to pay for it.

Why urine source separation?

Human excrements are the greatest source of nutrients in wastewater, and the major fraction of excreted nutrients is found in urine (Figure 2). Although the numbers can vary, urine typically contributes around 80% of the nitrogen, 50% of the phosphorus, and 90% of the potassium in the total nutrient load arriving at a treatment plant. This input can have a pronounced effect on the maximum daily load of ammonia with which the plant has to cope, and the urine peak early in the morning when most people get up is an important factor for planning plant capacity.

Absent urine, plant influent carbon and nitrogen levels would be almost balanced; that is, the plant’s bacteria feeding on the organic matter in the wastewater could absorb all the nitrogen content. Excess phosphorus remaining after biological treatment can easily be reduced. Production of inert sludge is thereby reduced, enabling savings in sludge handling and especially in ash disposal from sludge incineration, which is on the way to becoming the primary sludge disposal option, at least in Europe.

Urine is also the main culprit for the acute toxicity effect that occurs when there are combined sewer overflows. Most industrialized countries transport municipal wastewater and rainwater in the same (combined) sewers. During heavy rains, the total amount of sewage arriving at a treatment plant can exceed its capacity, and raw sewage, diluted by rainwater, is released directly into rivers and lakes. The discharge contains ammonia, a byproduct of urine decomposition, which is acutely toxic to fish.

Although a problem when released unintentionally to the environment, under other circumstances, urine provides definite benefits. Nitrogen, phosphorus, potassium, and sulfur are basic constituents of synthetic mineral fertilizers used in agriculture. Substituting urine components for these fertilizers eliminates environmental impacts associated with production and use of the latter and slows resource depletion (see box, "Advantages of nutrient recycling" (5)).

Other resource demand problems can also be avoided. For example, nitrogen is in plentiful supply in the atmosphere, but its industrial fixation is energy-intensive. As an alternative, urine provides a ready source of fixed nitrogen.

In summary, the economic and environmental advantages of adopting urine source separation are manifold: smaller, simpler treatment plants; lower nutrient emissions to rivers, lakes, and oceans; reduced sludge production; reduced use of flocculation chemicals, which saves money and reduces environmental impacts; natural resource conservation; lower fertilizer impacts; and greatly reduced toxic impacts of combined sewer overflows.

System mechanics

The NoMix toilet has one compartment for feces and one for urine. The urine flows through separate pipes to a storage tank that is emptied periodically. An alternative currently being explored is storing a day’s worth of urine within the toilet for later controlled release through the existing pipes in the building.

NoMix toilets already exist in Scandinavia, notably Sweden. There, a low-tech approach has been chosen for urine transport and treatment. Storage is decentralized and uses large tanks that are periodically emptied by local farmers who spread the urine directly on their fields (6).

The technology variant being researched at EAWAG is adapted to a municipal setting and relies on smaller, on-site storage tanks and use of the existing sewer network for transport to a treatment facility. Depending on the intended use, urine transport could occur at different times of the day. If urine is to be entirely removed from the wastewater stream for nutrient recycling, it could be released at night when the sewers are empty (Figure 2). This would require using storage tanks large enough to bridge a series of rainy nights. The Swiss urine-to-fertilizer strategy emphasizes processing of the urine solution. Sterilization, pH stabilization, removal of potentially harmful micropollutants, and the elimination of the characteristic odor are important treatment steps.

An alternative, low-cost approach for reducing the early-morning urine peak, involves temporarily separating urine using small storage tanks that are fully integrated into the toilet. The stored urine is released later during the day to ensure that a smooth, even load arrives at the treatment plant. Release could also be controlled to withhold urine when combined sewer overflows are likely to occur, thus reducing the adverse effects of raw sewage emissions to rivers and lakes. Modeling of this option shows that it could successfully compete with the more traditional approach of enlarging treatment plants and rainwater storage capacity (7). This strategy enables technological learning, especially in the area of real-time control, beginning with simple strategies like peak-shaving, followed by more advanced strategies for better response to rain events.

Stakeholders

Implementation of NoMix technology is not cost-free, even though it can use existing infrastructure. Investment is necessary at the household level, in particular, when the nutrient recycling option is pursued. NoMix toilets could be installed in the course of natural appliance turnover, but piping and storage are bigger items to consider, and additional treatment facilities would have to be built. To accomplish all this, multiple parties have to realize a stake in the new technology.

Although its marketability has not yet been tested, producers of sanitary appliances and equipment are already investing in NoMix technology (8, 9). The first generation of NoMix toilets was produced by small Scandinavian companies; the type shown in the photo at the top of this page and Figure 3 was produced by Roediger Vakuum + Haustechnik (www.roevac.de), a German manufacturer. Several Swiss firms have shown interest in a toilet with integrated storage.

Consumers who participate in pilot projects have responded favorably to the NoMix technology, despite some minor technical difficulties (10, 11). The technology saves them money by conserving water—flushing urine in the NoMix toilet requires 0.0–0.2 L, whereas a modern water-saving toilet uses 2–3 L for a small flush. On a daily basis, a family of four could save around 80 L of water. Given typical Swiss water prices, annual savings of $100 (USD) can be realized—double that amount, if the toilet to be replaced is not of the modern, water-saving kind. Household investment in NoMix technology could be amortized over 5–10 years.

Public authorities will have to act if urine separation technology is to grow more rapidly. Consumers can install NoMix toilets but still need the involvement of regulatory agencies and wastewater service providers. If existing sewers are used for transport, storage tank opening should be coordinated with treatment plant operations. Moreover, urine storage and treatment require new infrastructure, particularly if the nutrient-recycling option is pursued.

Public authorities should have an interest in pursuing NoMix technology, because it can significantly improve treatment plant effluent quality. Using NoMix technology to level the ammonia peaks produces the same effect as expanding treatment capacity, either reducing the ammonia and nitrite content of the effluent, or allowing for additional nitrogen elimination (12). In some countries, denitrification to reduce nitrogen in plant effluent has been mandated to prevent further ocean eutrophication. This expensive end-of-pipe measure would be redundant, and its effect easily surpassed, if urine were removed at the source.

The attraction of urine-based fertilizer for farmers is more tenuous, since they are not yet affected by shortcomings of the present system. Containment of heavy metals might be the most relevant issue for them. Organic farmers could find the urine-based fertilizer a welcome source of nutrients, since the organic certification requirements they have to meet often prohibit using synthetic mineral fertilizers (13). Any use of urine-based fertilizer on the farm should be preceded by an assessment of associated ecotoxicological risks; for example, microresidues in urine (pharmaceuticals and hormones) may have to be removed from the fertilizer product. Such a risk assessment is being carried out by the EAWAG NOVAQUATIS project.

For several years, the phosphate industry has been exploring alternative sources for raw phosphate, for example, phosphate reclamation from wastewater and chicken manure. Although the industry has not yet shown an interest in phosphates reclaimed from source-separated urine, it might soon begin to do so. The industry’s interest in alternative raw material sources is driven by increasing difficulties with disposing of hazardous wastes generated during phosphate rock refining.

Although EAWAG scientists and associated institutions do not have a direct commercial interest in the NoMix technology, they are stakeholders nevertheless, exploring alternatives to current materials policy. In the NOVAQUATIS project, engineers are developing treatment methods for separated urine solutions to make its constituent nutrients available for agriculture. Microbiologists and agricultural ecologists are studying the ecotoxicological risks that a urine-derived fertilizer could bring to soils and plants. Environmental scientists are assessing material flows associated with conventional and nutrient-separated waste management regimes. Economists and social scientists are exploring the acceptance of the technology, taking into account cost and consumer attitudes.

Next steps

Urine source separation is but one step toward a more comprehensive source separation strategy that makes it easier to treat and recycle wastewater stream components. Because individually they are more homogeneous, wastewater components can be better controlled if they have not been mixed.

Ecological engineering approaches that use ecosystems for engineering tasks and exploit their self-organizing capacity (14, 15) likewise benefit from, and increasingly rely on, source separation. For example, separation of urine and feces leaves “gray water” that can be more easily treated in constructed wetlands.

In the future, source separation may permit the use of completely decentralized wastewater treatment systems that avoid transport altogether. Already, the relative ease of accomplishing urine source separation in an existing, inert system permits implementation to occur, though gradually, and positive effects are being realized from the start.

To move toward really intelligent wastewater management, however, change has to be more radical. The principle of source separation could be extended to other household wastewater sources. The major water-using appliances in the household—toilet, washing machine, and dishwasher—are responsible for at least 85% of the organic pollutant load in residential wastewater. Equipping these appliances with a device for internal waste reclamation would be a logical way of reducing pollutant emissions from wastewater. Recent developments in membrane technology and other physical–chemical treatment methods hint that such solutions may be realistic in the not-too-distant future (16). Use of technologically sophisticated appliances such as these would leave households with small remaining amounts of wastewater that could be treated on-site to a quality comparable with rainwater. In this scenario, public responsibility for wastewater transport and treatment would be largely delegated to households, opening up a mass market for in-house water treatment technology that could provide greater rewards for innovation than the large-scale infrastructure of today. Such radical source separation could also alleviate the burden of dealing with contaminated biosolids, because with separated waste streams, the resulting separate fractions of biosolids would be of higher quality and could be directed toward their most suitable destination.

Taking source separation seriously, handling all wastewater components individually, and reducing the associated water use pose a real challenge. At some point, we may want to downsize the entire urban water infrastructure or do away with it altogether. This cannot happen overnight, but if we don’t start the journey now, we will never get there.

Advantages of nutrient recycling

Current fertilizer production and use consume limited resources and harm the environment. At current extraction rates, reserves of phosphate rock that are economically recoverable with today’s technology will last less than 100 years, and the reserve base will last less than 300 years (http://minerals.usgs.gov/minerals/pubs/commodity).

In addition to resource limits, phosphate rock has a high heavy metal content, giving rise to hazardous wastes when processed. The cadmium content of phosphate rock, for example, ranges from 0.1 to 850 mg cadmium per kilogram phosphorus. Because these impurities are not entirely removed from the final product, phosphate fertilizer application introduces heavy metals, such as cadmium, which is very toxic, into the soil. This problem will worsen if rock of lesser quality is used in the future as the resource is expended. There are also impacts associated with hauling raw materials long distances to where they are needed, as well as after their consumption, when nutrients are discharged into lakes, rivers, and oceans, where they cause pollution and are largely unavailable for use in agriculture.

Clearly, a closed nutrient cycle is desirable (7), and some nutrient recycling is already happening. For instance, in many places, sewage sludge is being spread on agricultural fields. The sludge acts as a fertilizer, but the practice primarily serves as a cheap disposal option. Given the increasing contamination of sewage sludge with pollutants from municipal wastewater, its application to fields is increasingly less viable (Environ. Sci. Technol. 2000, 34 (19), 430A–435A). Source separating urine could reopen this pathway for agricultural application of nutrients recovered from municipal wastewater treatment and avoid the current problem of effluents from treatment plants contributing significantly to nutrient pollution of water bodies.

References

1. Ternes, T. A. Water Res. 1998, 32 (11), 3245–3260.
2. Stumpf, M.; Ternes, T. A. Vom Wasser. 1996, 87, 251–261.
3. Pharmaceuticals and Personal Care Products in the Environment: Scientific and Regulatory Issues. Daughton, C. G., Jones-Lepp, T., Eds.; American Chemical Society: Washington, DC, 2001.
4. Ashfield, L. A.; Pottinger, T. G.; Sumpter, J. P. Environ. Toxicol. Chem. 1998, 17 (3), 679–685.
5. Beck, M. B.; Cummings, R. G. Habitat Intl. 1996, 20 (3), 405–420.
6. Höglund, C.; Stenström, T. A.; Jönsson, H.; Sundin, A. Water Sci. Technol. 1998, 38 (6), 17–25.
7. Larsen, T. A.; Rauch, W.; Gujer, W. Waste design paves the way for sustainable urban wastewater management, submitted to the UNESCO Symposium Frontiers in Urban Water Management: Deadlock or Hope?, Marseille, France, June 18–20, 2001.
8. Fussler, C. Driving Eco-Innovation; Pitman Publishing: London, 1996.
9. Moore, C.; Miller, A. Green Gold: Japan, Germany, the United States, and the Race for Environmental Technology; Beacon Press: Boston, 1995.
10. Burström, A.; Jönsson, H. Double Flushed Urine Separating Toilets—User Experiences and a Follow-Up of Problems; Report 229, ISSN 00283-0086; Swedish University of Agricultural Sciences, Department of Agricultural Engineering: Uppsala, Sweden, 1998.
11. Hanäus, J.; Hellström, D.; Johansson, E. Water Sci. Technol. 1997, 35 (9), 153–160.
12. Larsen, T. A.; Gujer, W. Water Sci. Technol. 1996, 34 (3–4), 87–94.
13. Haller, M. Düngeverhalten von Bio- und IP-Landwirten (Fertilizer Use by Farmers in Switzerland); Department of Environmental Sciences, Swiss Federal Institute of Technology: Zürich, 2000.
14. Ecological Engineering: An Introduction to Ecotechnology; Mitsch, W. J., Jorgensen, S. E., Eds.; Wiley and Sons: New York, 1989.
15. Ecological Engineering for Wastewater Treatment; Etnier, C., Guterstam, B., Eds.; Lewis Publishers: Boca Raton, FL, 1997.
16. Larsen, T. A.; Gujer, W. In Water Resources and Waste Management. Conference Preprint of the 1st World Congress of the International Water Association, July 3–7, 2000, Paris; 2000, 5, 293–300.

All authors are at the Swiss Federal Institute for Environmental Science and Technology (EAWAG), Dübendorf, Switzerland, and are part of the NOVAQUATIS management team. Tove A. Larsen (tove.larsen@eawag.ch) is an environmental engineer in the Urban Hydrology Division of EAWAG and leader of the entire NOVAQUATIS project; Irene Peters is an economist in the Systems Analysis, Integrated Assess ment, and Modelling Division and heads a project conducting a comprehensive evaluation of all aspects of the NoMix technology, Alfredo Alder is an analytical chemist in the Chemical Pollutants Division and coordinates a project analyzing the fate of various pharmaceuticals in urine; Rik Eggen is a molecular biologist heading the Environmental Microbiology and Molecular Ecotoxicology Division and coordinates the projects on the potential ecotoxicological effects of substances in urine; Max Maurer is a process engineer in the Environmental Engineering Division and coordinates the projects exploring methods to process the urine solution; and Jane Muncke, an environmental scientist, is working on the effects of conventional versus urine-based fertilizers and is also assistant to the project leader.

Diesel Exaust PM10 Rule Compliance Letter.

2006-03-05T13:59:00.000-08:00

Junk Science-Extensive Air Pollution From 1.6 Million Desel Truck Miles Per Year to pump septic tanks ignores new federal guidelines for spot air pollution. RWQCB not in contact with EPA Air about EPA Air Regs!
Junk Science-Removing water from septic tanks removes 25 MILLION gallons of water per year from the water basin causing further salt water intrusion and causing increased ground water degradation.(2800 Homes x6 pumpings/year x1500 Gallons/home= 25,000,000 Gallons/yr.) Duh?

Dear Ms. Patuliski
EPA AIR POLLUTION RULES ADMINISTRATION,

It has been brought to our attention that PM10 conformity rules may be in question concerning non-sustainable solutions to the Central Coast RWQCB ruling to truck 2800 septic tank contents six times per year, per parcel, over 100 miles to conform with a cease and desist order subject to the Porter Cologne Act. Under that act the RWQCB is supposed to consider sustainable solutions. Does this burden the Los Osos corridor area spot Air pollution? Is there a compliance issue with your agency? Our estimate is 1.6 million Diesel truck miles per year will be driven to comply with the septic pumping order. (2800 x 6 x 100 Miles on Los Osos Valley road and Hwy.101) LVR is a 12 mile two lane commuting road and the intersection of LVR and highway 101 already congested with rush hour, Home Depot and Cosco traffic.The balance of the trucking will be on 101 to Santa Maria for disposal or possibly Bakersfield as a destination for each load of effluvium.

It is our estimation that these emissions are avoidable and based on limited scientific discovery. There is actually an increase of fixed nitrates and nitrites in the effluvium if solids are eliminated from the septic tanks. Nitrogen reduction from sewage waste is accomplished by high carbon to nitrogen biomass raitos relative to nitrogen content so nitrogen can be digested by bacteria to accomplish denitrification. EPA data suggest a ratio of 5 Carbon atoms in biosolids to 1 Nitrogen atom for denitrification as optimal(See Chapter 3 in link to EPA Septic Systems Manual.).

In essence we are increasing air pollution for nothing and that is why we are suggesting sustainable interim solutions and involving your office in this policy decision. We are concerned that the order wastes energy, pollutes the air, and does nothing for water quality. We are making specific recommendations removing N from the waste stream using EPA conforming sustainable on site solutions and NSF complying products under NSF standards 40 41, and 46 to meet interim N reduction avoiding air quality traffic issues entirely.

We are hoping you can lend us your support in this effort and are like minded about limiting truck miles to reduce ground water nirtogen to federally mandated levels already approved in the RWQCB discharge permit for the on hold sewer project. Butte County already is installing approved systems to meet Nitrogen requirements approved by the Water Board in that county? Our hired engineers can propose valid N reduction with empirical data and monitoring using NSF monitoring guidelines from Stds 40, and 41, greywater recycling, and water conservation. We hope you can convince the RWQCB likewise.

We would appreciate your input.

Steve Paige

Optimizing N Reduction Hyperlinks for the Non-Believers.........

2006-03-03T08:23:00.000-08:00

Energy Consumption for N reduction, Tri-W System flunks even without adding in the energy to lift all that water uphill to the 'Bogus'derson giant leachfield ( like the one in your yard but bigger and waaay uphill):
http://www.iwaponline.com/wst/04801/0037/048010037.pdf
EPA Federal is on board, what's wrong with these State guys:
http://www.epa.gov/ORD/NRMRL/pubs/625r00008/html/tfs9.htm
Full EPA site for on site treatment:
http://www.epa.gov/ORD/NRMRL/Pubs/625R00008/625R00008.htm
Small Flows Clearinghouse:
http://www.nesc.wvu.edu/nsfc/nsfc_index.htm
NSF Certified Products:
http://www.nsf.org/Certified/Common/Company.asp?Program=WSTWTR
NSF Ruling Standard- Standard 40 Discussion/Intro:
http://www.nsf.org/business/newsroom/regworld01-3/rw_page4.html
Scarry Energy Stuff:
http://www.npg.org/specialreports/bartlett_index.htm
http://www.oilcrisis.com/experts/
Same Poop- Double Standard. No disposal after 2010 for Homeowners- Sewer plant allowed to to recharge groundwater at 7mg/l Nitrogen with 'no measurable improvement for 30 years'. Your land is being stolen from you by punitive manipulation of the Porter Cologne Act. It has nothing to do with law or EPA guidelines. Be sure to send in your objection.

Will Peak Oil Economics will kill Tri-W?

2006-02-25T07:01:00.000-08:00

The post oil economy begins now.
http://www.oi lcr is is.com/
The scramble is on with 1.5 Billion Chinese jumping on the energy consumption bandwagon. Our per capita share of energy will have to drop by 50% in the next ten years to accommodate China and India. It's the law of supply and demand. You WILL pay double or more for the same amount of energy. Hence, if we continue pursue anything but zero energy waste solutions, small scale ecologically sound solutions, we will fall prey to the realities of energy economics. The O&M for the Tri-W project would have gone up 300% even before it could have been completed. Simply, it will become unaffordable to operate. Plus, the costs for constructing anything like the Tri-W project are totally out of control because of shortages derived from energy shortfalls right now. As a licenced General Contractor for 25 years I have never seen anything like it. Prices on construction materials are going through the roof. It's becoming unmanagable to give a fixed price on anything.

So if we want to have a functioning community in the near future we have to completely rethink how to clean up the ground water basin using near ZERO energy. With Tri-W, you have been sold a nineteen fifties solution in a 2100 century world by the same greed that has brought our federal government to the brink of corruption meltdown.

Let's think big for EVERYBODY a minute. Let's ponder that we want to remove 30% percent of the nitrates from our ground water and recharge the basin just like the Tri-W project with zero energy input. Could we do it? Yes......

First we remove every garbage disposal in Los Osos and set up community collection and composting. This cuts blackwater solids and BOD (wastewater oxygen demand) by fifty percent from the input side. Energy cost -ZERO. We take sink garbage out of the digestion loop. Now we have cut nitrates on the front end by 15%. Remember, Tri-W was only going to remove 30% of the nitrogen. (7mg/l vs. 10mg/l) We only have 15% more to go.

Next improve anaerobic digestion that occurs in your septic tank. A symbiotic relationship of five different micro-organisms is responsible for nitrate reduction in your septic tank. Over pumping your septic tank actually increases nitrates because it takes time for the biological community in your tank to actualize nitrogen assimilation.

The worst thing for the bioreaction is water surges like your washing machine or shower. Both are grey water development friendly. Even taking these loads and setting up surge tanks for them or bipass to the leachfield would help the bireaction of nitrates in the septic tank. Once you optimize the nitrogen metablism you are correctly optimizing nitrate reduction. Eliminating surges, garbage wastes, grease, and microbe killing household cleaners helps with anerobic digestion of nitrogen.

The next generation of residential nitrogen reduction will be small scale filter media beds. Basically large surface areas in small spaces for the anaerobic microbes to call home- Read here about modern anaerobic bioreactors, a step beyond septic tanks: http://www.brentw.com/water/modular.htm

There is no sound science supporting bi-monthly pumping that I can find. Bacteria eats nitrogen. Bacteria in the septic tank. Bacteria in the ground. Remove the bacteria in the septic tank and you INCREASE ionic nitrogen! Were did these guys get their Biology degree? If its solids reduction that the RWQCB is after then.......

Then we install solids filtration and pump the tanks every two years. This is just a first step. Again near ZERO energy consumption. It needs to be cleaned every two years and looked at every six months.

Now you still have blackwater with high oxygen demand so you install after the tank, but before the leachfield, an Aerobic digester. You oxygenate the water to add aerobic bacteria to the digestion process. You could do this with DC photovoltaic driven compressor pumps. What you are doing is the same thing you do with a fish tank. You bubble air in the water to calrify it. Again near ZERO energy consumption. (.5 to 3 KWH/day) This would cover all systems that had the correct groundwater separation in Los Osos. The end product is as clean as the Tri-W output water.

You would need a maintaince contract and a waste discharge permit from the RWQCB and possibly a deed restriction to carryover your maintaince program to the next buyer. But your O&M is purely human oversight and human labor at .5 killowatt per man day. Almost NO energy input. Savvy? A system like this is installed in 400 Texas residences and is approved for California use in the Chico area with problems similar to ours: http://www.clearstreamsystems.com/homesystem.html

So far I haven't suggested any owner oriented lifestyle changes except eliminating garbage disposals but if it was in the discharge permit and it would save you $175.00 per month you would consider it I bet.
Here is your Areobic primer:

Aerobic digestion (with molecular oxygen) is far more complete. Aerobic digestion takes place in a properly constructed and maintained drain, as well as in an aerobic treatment device (ATU). In an ATU, the aerobic bacteria are selected out from any remaining aerobic bacteria which survive the trip through the septic tank, or are facultative bacteria which can exist both with and without molecular oxygen, or are random seed bacteria which are everywhere in our environment. In the soil, there are hundreds of different types of organisms that proliferate in the trenches where there is a regular supply of nutrients (septic tank effluent). Biological mats develop on the sides and bottoms of the trenches and add to a biological filtration of the effluent passing through it into the soil environment. The structure of these mats are due in part to the long filaments often growing out of several common strains of soil bacteria. If biomats are improperly managed, the growth can become so thick that the pores in the soil structure surrounding the disposal trench can become clogged. With the right balance of molecular oxygen to influent, the biological mat can be maintained as a benefit to the water treatment, and the wastes can be degraded completely to carbon dioxide and water allowing the aerobic treatment to go to completion.

Aerobic treatment in a trench or in an ATU is complete digestion and can achieve the following reductions of influent contaminant levels:

Water Quality Parameter	% Removal In A Septic Tank
BOD (Biochemical Oxygen Demand)	75% to 90%
COD (Chemical Oxygen Demand)	75% to 90%
TSS (Total Suspended Solids)	75% to 90%
Ammonia (Changed to Nitrate - N)	80% to 90%
Enteric Bacteria	generally high but variable
Enteroviruses	generally high but variable
Protozoa	generally high but variable

So how does this measure up to Tri-W? Zero energy consumption. Equal or better water clarity and nitrate cleanup. Diffuse groundwater recharge. No real lifestyle change. And you don't have to kick out all the poor people in Los Osos to pay for it. For about 12,000 dollars per parcel or 12,000X2900=34 Million dollars for existing homes.

Low lying systems, the more pricey properties near the bay, would need pressurized ET wetland leachfields with lined, covered, beds or micro community plants with energy input a prime design factor.

Recharge? How about recharge credits by leaving the water in the ground. What is a recharge credit worth when just outside the city farmer's are allowed to pump all the water they want?
The real problem with the basin ground water managment is the legal structure that allows rampant pollution and consumption by Agriculture and squeezes urban users to make up for it. But that's another topic.

The incredible melting town

2006-02-22T19:10:00.000-08:00

We have a very serious issue here folks,
To be or not to be-
Probably one of the most overused cliches of all time.

In Los Osos it will become a very real question.

Should we ask LAFCO to dissolve our CSD?
I'm hoping the comment section gives us substance to hold on to.

Not conjecture or opinion without merit

Base your statements on facts

If its your opinion, say so.

Thanks for participating.

Mike Green

2006-02-08T20:11:00.000-08:00

All quiet on the Western front.

No real news to report from Los Osos except the Tree man Saga, and at Ann's blog about (non existant) community values.
And Ron, my friend is still asking some important questions. I wish him luck, He will need it.

I'm still playing with this blog stuff, I got a few good replies last time, so I thought I'd try someting else.

What, was your first sewer experience?

You see, I am trying to help our poor community by giving everyone an outlet for their feelings, to lessen the load, to get a chuckle.

Ok, Here is mine.

It was 1973 and I was 16 & I was an usher at the local drive in theater.
My job was to wear a white coat and red hat, ride a bicycle around the lot during the movie, supposedly upholding the rules, watching the kids at the playground during intermission and do generally anything the manager told me to

It happened one night that the men's urinal got clogged up.
Back then a urinal was a large oval tub bolted to the wall with a steady stream of water trickling down from a horizontal pipe with lots of holes in it.

Willie, my manager who was like a second mother to me,
caught me on the way through the snack bar.

"Mike, I need you to unclog the men's urinal"

I must have looked like a deer caught in the headlights, because she took me by the hand, issued me a mumbly-plunger and a set of huge gloves.

I went to the bathroom to confront the beast,
It was a foot deep in a sickening yellow liquid

There had to be a better way!

As I passed by the projectionist booth I spied my salvation.

Back then, the projectors were powered by arc- lights
Herman, the projectionest would keep a bottle of compressed CO2, which we used for soft drinks, with a hose and a hand nozzle near by to blow away the occasional dust that would obscure the lens.

The thought came to me to instead of manually pushing the clog down, BLOW IT DOWN!

I snitched the bottle and rig.

Well it worked, after giving it a good long shot of compressed CO2 though the drain with a towel wrapped tight around the nozzle it drained right out!

I cleaned up and took my station at the popcorn popper to get bags of popcorn ready for intermission.

"Hey Buddy" "we need paper towels" was my first order.
along with the next and the next and the next.

Willie came up to me .
"Mike, what did you do?"
After explainig myself,
And Willie could catch her breath.
She told me about "vents"
Which aparently exited through the roof of the snack bar!

Well!

This is a true story

I heard it looked kind of like a volcano

No one was hurt as far as I know
It was a far safer time

2006-02-01T19:44:00.000-08:00

Have at it! this post is to accept all comments about the hideous sewer wars.
My friend Ron, has turned off the comment section of his blog and I don't blame him.
He takes his writing seriously, I can understand that.
When you write a blog, you are putting it out there.

Me? I'm a car mechanic.

I have no pretense of writing skills

But I do have a weird sense of humor that some people seem to apreciate.

So what I thought would be amusing is to let the insane run the asylum

What is your most insane solution to the Los Osos wastewater problem?

Mine, is to give all our houses back to the Chumash

Imagine the great casino sitting on top of the underground sewer on the Tri W site with ample parking too

Of course, I would like a 1 dollar a year renewable and transferable lease.

A world of our own

2006-01-03T20:03:00.000-08:00

Back from the holidays!
Did the relative reunion thing up in Washington.
Had a great time being there of course, little kids around the tree, huge feasts, laughter.
Had a rough time getting there and back, flew commercial, delays in San Francisco caused airliner back-up that went into extra days.
Could have drove faster, Oh well--

Dose it happen to you?
When you visit someplace else, do you see things with "Los Osos" eyes?
Like running someone else's garbage disposer, you watch it disappear and think "Wow, modern living!"
You stop and stare at manhole covers
You secretly hope that they leave a sewer bill lying around face up
You read their local paper with particular attention to the crime and local politics.
Can you imagine the San Francisco Chronicle reporting crime ala "Bay News" Style?
I took a Bay News with me on the trip and left it on the coffee table
Hoo, was that funny!

We eventually made it home
Our bags? later.
And it was raining and blowing
As we drove by the Tri W site we saw that the tarps were all blown straight out,
kind of reminded me of a Marilyn Monroe picture.
A peek at something secret.
And there they were!
The Ponds Of Avalon!
The Dig had filled with water, there were at least three large pools.
Kind of ironic, doncha think?
Finally home.

Washington was wet and very green
But here I can hear the ocean,
when the waves are big, or when the tide is low.
It's my favorite noise
I particularly like living near the beach,
I was thinking about this blog before I left for Washington,
since I don't really have any huge agenda, I was thinking of writing about critters in our area
Everyone likes animal stories. (Don't they?)
So I thought I'd start with our westernmost denizens
In reality they live in Montana De Oro.
But, I Think Los Osos includes that park
Remember the time the County was going to let the State Parks people take over Pecho road and put up a toll booth?
That town meeting with Bud Laurent and the State Parks Rep. was as close to a tar and feathering I've seen.

Anyway, I was going to pick Sandcrabs
Lowly Common Sandcrabs
I know a few things about them, but I knew I needed to brush up on my marine biology, so I googled 'em
There in front of me (and I'm not making this up)
The Third web site down was
http://www.fortbendnow.com/sports/203/
Calhoun Sandcrabs!
That lady gets around!
Kind of ruined my train of thought.

So next time I'm going to pick the Turkey Vultures.

Oh, by the way, I saw a bumper sticker yesterday, on a pickup truck

Los Osos
We can't agree about sh*t

Either that was one of our commentors, or people really DO read this stuff.

Where can I get one?
Mike Green

A World Of Our Own

2005-12-18T13:48:00.000-08:00

by Mike Green

First off, I want to thank Newsstand Greg and the Central Coast News Mission. And, to ask for tolerance from the great band of bloggers already here. I'll do my best to uphold the fine level of journalism that exists here, but I am a beginner, with scant training. Give me a chance, I'm a very quick learner.

What can I possibly contribute to the already well documented "Great Sewer Wars?" Well, after Ann and Steve and Ron get done grinding the minutae to it's molecular subcomponents, and the comment bloggers, (Shark Inlet, Spectator, Dogpatch refugee and others) add thier expertise and opinion--not much.

So what will I write about? Well, "The Sewer Wars" of course. Heck, I live here, It's like watching home movies. It's easy too, almost unlimited material.

But that's not everything. I want to share what is good and right about my Home -Town, -Community, -Local area. Lets face it, Los Osos defies a normal definition. Some call it "Paradise," some "a backward bunch of scofflaws."

I call it a world of our own.

So, for now, I'll call this a test blog. Oh, by the way, I encourage comments, good and bad. That's how I got started.

--Mike Green

How To Make $50,000 In Three Minutes

2005-12-03T18:24:00.000-08:00

Here's my get richer quick scheme. It has to do with the equity you have in your Los Osos home. I guarantee that if you do your homework, present your information to the new Los Osos CSD board and request them to tow the line on proposition 218, your property will be worth that much more when the next sewer is funded.

Your equity under fire. While you were squabbling over where to put the sewer and how it was to be designed one of the biggest tax assessment scams in the history of California was going on right under your nose. Over $100,000,000 dollars of our equity was potentially assessed in conflict with California Constitutional law.

The cover up continues. The SRF lender, the State, has called for a two thirds vote on the Los Osos sewer project. It's a tacid admission that the loan paper trail hides the fact that you were being ripped off. I'm doggedly persuing the paper trail but it will take time. Here's the potential list of State Constitutional law violations stealing your assessment rights:

Original loan application states NA for “Not Applicable” where asked if vote was taken.
No input is made as required on the SWQCB input checklist about voters.
No division of general vs. special taxes.
Engineers report eventually characterizes revenue stream as an assessment.
No vote on cost increase from $47 to $69 Million Approved by resolution.
No section 4 compliance on increased funding resolution.
No bifurcation of special vs. general taxes on increased funding resolution.
No mailing of calculated assessment with voting card on increased funding resolution.
No record of vote on increased funding resolution.
No vote on cost increase Resolution from $69 million to $97 million.
No section 4 compliance on second increased funding resolution.
No bifurcation of special vs. general taxes on increased funding resolution.
No record of vote on increased funding resolution.
SWQCB requests August 25 2005 LOCSD supply “Reimbursement Resolution”.
No Resolution was ever supplied.
Agency Reimbursement Resolution is missing in contract documents, Exhibit L.
Loan is funded anyway.
SWRCB attempts to repair reimbursement policy of the LOCSD after the fact, by unilaterally demanding a 2/3 vote.

Here's where the State Constitution could save you seventy dollars a month and increases your equity by $50,000.The original engineering report charcterizes project funding as an "assessment" and the criteria for the SRF federal loan is that a portion of the money MUST go to Estuary improvement to get the loan. (The figure I have been hearing is 1/3).

Then according to prop.218 your sewer bill would be reduced by that 1/3 because that money is required to come from the "general tax" fund and cannot be billed to your property as a "special tax". You just took three minutes of your time to point out the fact to the new LOCSD. Your sewer bill just went down by one third. Your property equity just went up by $50,000. Look at the home prices in Morro Bay and Cayucos. Home prices in Los Osos are way less. If you push for prop.218 compliance they will rise to be more in line with like properties in the area. But you must do your part.

The project is halted because about $100,000,000 dollars of it was slid under the Prop. 218 table. It's a total fallacy that the new board scuttled the loan. The SWRCB got cold feet on their Prop. 218 'negligence'. THEY are the lender responsible for all the paper work being straight. THEY got frightened about this loan. The State is supposed oversee and administer the loan so it is in compliance with 'state law'. That's a little like letting the fox watch the sewer house. What we ended up with was a fox caught red-handed with prop 218. shredded in its jaws. Why do you think they are NOW demanding a 2/3 vote on the sewer project? They really have to go back to the base cost of the loan when the loan application was turned in and start from square one.

The loan needs to be rectified with State law. And that's where you can make $50,000 in three minutes. Not only can we decide what is an affordable sewer, we also can set a limit on what will be spent. Any cost increase has to again be approved by the voters. It's all in prop. 218. EPA benchmark cost for your sewer is 4% of your income. They are the original lender. So figure that is about what you should pay. The Code is here: ARTICLE XIII D

Here's where you can protect your home equity. These are the requirements for assessments under Prop. 218. The measure places extensive requirements on local governments charging assessments. Specifically, the measure requires all new or increased assessments--and some existing assessments--to meet four conditions.

First, local governments must estimate the amount of "special benefit" landowners receive--or would receive--from a project or service. Special benefit is defined as a particular benefit to land and buildings, not a general benefit to the public at large or a general increase in property values. If a project provides both special benefits and general benefits, a local government may charge landowners only for the cost of providing the special benefit. Local government must use general revenues (such as taxes) to pay the remaining portion of the project or service's cost, i.e., bay pollution improvments.

"Chinatown" The Movie, Revisited

2005-11-23T05:21:00.000-08:00

Three minutes is not a long time to expose ten years of hanky-panky but there I was last night trying to sum it up. After taking my flea comb through the 51 page loan agreement between the CSD and the SWQCB and reviewing the new conditions of the proposed continuance of the loan it struck me just what went down.

You could drive a truck full of money through the Revenue Stream clause. In effect, the CSD would not have to figure out how they are going to pay back the loan till 90% of the sewer plant was complete. This is like the bank loaning you money for your house and saying hey, we'll look at your credit and figure out if you can pay us back after you get your final inspection.

Bingo. The SWQCB knew about the revenue stream shell game. There are two ways to get revenue for the sewer. Through "user fees" or through "assessments." Proposition 218 creates a firewall between your pocketbook and the CSD. Each type of revenue stream has a list of constraints. Now like I said before, follow the money.

The Sewer starts out as an assessment district with the County. It's on your tax bill. That's for the original engineering study. We still owe $17 million on that one. Watch carefully. Shazam! The revenue stream becomes a "user fee." As a "user fee" they can raise the price of the project with no oversight.

Forty million, then sixty million, then 90 million, then 130 million, etc, etc, etc. One problem, they can't charge the vacant lots. Ooops! That means that 5000 households will be paying for unused capacity on lots that are idle. And it's quite possible that the vacant lots will never be built on because of salt water intrusion.

Along comes the new board and Measure B. Now keep your eyes peeled..... Woosh! The SWQCB demands that the loan revenue stream be under the "assessment" shell. Now the SWQCB can get their money back because they can charge the vacant lots claiming it's not their fault that you can't build on them.

Let's imagine for a minute that this was all played out in the e-mail alley behind the CSD office. The SWQCB had motive. Shortsightedly, they thought they would benefit by the "user fee" revenue stream because there would be no special vs. general tax separation. They had been touting for years that the sewer was a major part of the basin plan and Estuary improvements.

If the taxes were separated between general and special, it's quite likely the sewer could never be financed. The LOCSD-3W had motive. By calling the revenue stream a "user fee" they could run up the cost 300% without any vote by the people.

So I'm looking at this 51 page contract that is so hair splitting that it makes sure your employee's ex-wife has toothpaste money. The $130 million, drive through, 'don't-tell-me-how-you-are-getting-the-money-till-it's-done' clause looks a little fishy. Don't you think? Well, it all might have gone down that way except the money stream now is a "user fee" so they're stuck with Prop. 218 "user fee" constraints:

-They can't charge you for your vacant lot.
-You can opt out on hooking up.
-You can't be billed till they deliver the service.

But "user fee" constraints offer even another firewall. If you can get the service generally elsewhere, they can't charge you for it. Which means you could put in your own on site wasterwater treatment plant for say 75 dollars a month with a guy that comes around and logs that your system is twice as good as the sewer plant, like this one: The Equaris. That's a BIG problem. It's called competition.

So why is the SWQCB flipping back to "assessment" model? So the SWQCB has some place to get their money from. You think they got caught and now they have to run the Prop. 218 "assessment" gauntlet. Wrong. Actually they are switching horses, mid sewer apocalypse, to stick you with the bill. I saw the bit about the two-thirds vote in the SWQCB's conditions but I didn't see any mention about the tax separation--did you? Funny thing.

Do you believe the loan payment source can be flipflopped between revenue methods purely to avoid Prop.218 constraints? That is how your property rights were abridged. Now it's time for, as they say in the legal profession, discovery. That is why we need the State and Federal and Grand Jury to look in that alley and find out who walked all over our property rights.

Special thanks to the HJTA for the inside info. --Steve Paige

What To Do When The Titanic Sewer LoanHits A Proposition 218 Iceberg

2005-11-19T06:17:00.000-08:00

The Los Osos sewer loan is sinking. Everybody's in a panic running for the legal life boats. As a third class passenger, many of you are afraid for your financial lives. Don't panic.

Thirty three percent of the families out here are living below the poverty level. That's why Baywood Elementary is a Title I School. Another 20 percent are Seniors on a fixed income. We are in the majority. Prop. 218 was written for us.

Proposition 218 seemed like a weenie little problem but the wackos floated a loan that was so structurally unsound that it immediately started to sink when it nudged aginst measure B. To ask the right questions we have to follow the money. The State water board is asking the LOCSD to get out of the last legal lifeboat so that the SWQCB can paddle off to safety and avoid the follow the money sctutiny.

How are they doing this? By offering 150 million dollars in 'funny money' to the LOCSD to get out of the life boat and go down with the sinking loan ship. The loan is dead either way because of Prop. 218 irregularties. Oh, also, they have henchmen pointing hefty fines at the LOCSD to blow them away if they don't agree. To me that's really a rock and a hard place. Where are we in all of this? Well actually, we are in really good shape.

Here's why.

First you are only looking at the tip of the legal iceberg. Proposition 218 was an initiative that we the people passed to close loopholes in the Gann Initiative, Prop. 13. It's supposed to protect you from bogus "special taxes" on your property by having you vote on them. It's a surprisingly simple, very readable amendment to the State Constitution that protects you from being over taxed for services delivered to your property.

Second, the 150 million dollar loan is 'funny money'. It's quite possible that the loan was agreed to and dispersed outside of its Proposition 218 constraints. That's why you smell panic among the ships SWQCB financial officers.

Stay calm, here's the instructions for your life preserver:

Formost read this analysis of Prop 218 from the State Legislative Analyst's Office. Then get ticked off. Then go to the County website and download the complaint for the Grand Jury and fill one out using Prop. 218 as your beef. Pick any section, almost all of them were violated by the wild CSD and SWQCB pirate swashbucklers who took over the ship and rammed the loan into Prop. 218. Given the situation I commend the new board for valor beyond the call of duty.

If the CSD caves in, it doesn't end the 218 drama, they just become the fall guy. If the County takes over the sewer project, it doesn't quelch the loan irregularties because they get stuck holding the rotten loan bag. That loan is the real hot potato, not the sewer location. I say it's your duty to complain. It doesn't cost a penny.

Then go to the State Tax Advocate’s web site and file for a hearing. The hearing is local. Doesn't matter which side you are on, sewer here or sewer there. We all have the same rights. It's your right to be taxed according to the letter of the law. Somebody blew it and you need make a stink.

I sent to the RSWQCB a little seven page note about what I think about their fines. I'm not waving a sewer flag. I'm waving a property rights flag. You and I, the low income majority in Los Osos, should have that flag to rally around. Read the fine print. Not one penny can be charged to you for a service that is not specific to you and actually being delivered to your property. That's part of Prop. 218.

I plan to stay here. This is a beautiful place to raise my child. I plan to squawk until I get my first 'reasonable' and 'legal' sewer bill arrives in the mail. Prop. 218 will assure me of that. I want to thank Newsstand Greg for letting me blog here and giving you my take on things. More to come about your own on-site 'Bio-neering' to help solve the sewer issue and how to be a thorn in the side of bureauracy.

NEXT: So why are you smirking outside the prohibition zone? I guess you haven't seen the new septic regulations that are being proposed by the SWQCB.

--your friend next door, Steve Paige

COOGERS And The Los Osos CSD-Three

2005-09-12T15:28:00.000-07:00

That Los Osos CSD-three, I'll tell ya, they sure know what's important! That's why they built a brand new million-dollar skate park for the out-of-town thugs who now hang out near the ATM around midnight on Los Osos Valley Road. Of course, this was done while a pipe at 8th st and El Morro ave has been dumping to the bay for 7 1/2 years without an NPDES Permit! Is this a great town or what?!

But don't answer yet folks, because the CSD-three are about to vote themselves the bond money tomorrow (voted 9/12/05--ed.) morning to scrape the hell out of the Tri-W proposed sewer site, even though it is going to kill, maim, and bury alive all the creatures there, and there are plenty! And this is all gonna be done by 3 guys who will be out of government forever in exactly 12 days!

C'mon, ya just gotta love that tender-hearted 'environmentalist' Gordon Hensley, member of the 'Waterkeeper Organization.'

And three cheers for the Los Osos CSD-three's 'P.I.O' (Public Information Officer, or as I call him, 'LIAR for HIRE'. Everyone got soooo mad about the baby deer pictures I sent out that he went on the defensive on TV, saying:

"Some sick individual dragged that deer to the construction site!" (That's an actual quote!)

And then, there's the hurricane. No, not Katrina, MARLA! Hurricane Marla Jo Bruton, member of the C.O.O.G.ers (Central Coast Ocean Outfall Group). We mosey'd into the Central Coast Regional Water Quality Control Board meeting yesterday morning, all the 'COOGERS,' just in time to find out that public comment was to be held at 1:30 pm!! This was at 8:30 am.

Well, that may be ok for the 'tamer' folk, but not for the COOGERS!

Hurrican Marla Jo did begin to blow! Briggs, Young, Les Bowker, they all sat up there in puzzlement as to why this nice young lady was standing quietly at the podium michrophone as the meeting dragged on, and finally they asked her why. Tee hee.

Gale force winds arose as Marla Jo explained about how we were from "out of town", and "when did you start putting public comments off" and "you are discouraging the public from participating" and jeeze, that was enough! Les Bowker called for a RWQCB huddle! They stopped the meeting, and came back and gave us our public comment at 10:00 am! Only then did the winds subside. I told them all about my regional plan (as if they didn't know) and how I "Looked Forward to working with the board."

I heard later from activists that public comment for everyone else wound up being held at 4:30 pm! Folks, the squeaky wheel gets the grease! Thank you Hurricane Marla!

Well, I'll see ya all out there on the corner of Los Osos Valley Road and South Bay Blvd, for the next 14 straight days 'till the election! C'mon down and listen to my new megaphone! Its L-O-U-D, you can ask the CHP, they told me! I've started wearing white shirts and ties--it's kinda classy, like an old-time newspaper editor. Maybe I'll get some suspenders. Nah-they might think I'm the D.A.

And the newest chant is:

"WE WANT A NEWER SEWER and THATS NO MANURE!"

"Now Re- Re-Call, Re-Re- Re-Call, Recall!"

love your pal, joey

When The People Lead, The Leaders Will Follow

2005-08-19T16:54:00.000-07:00

photo by NOAA
The countdown has begun. Each day that passes, the citizens of Los Osos are closer to self-determination with another vote: Measures B, C, D and E. Absentee voting by mail begins 8/29/05, and ends 9/20/05.

Once, I thought taking control of the "county waste water treatment plans" meant successfully voting into existence a community services district. Didn't happen on the first try. That was tough.

It appears that was not enough. Now, three members of the current LOCSD board face a recall election date with destiny, 9/27/05. Public protests now occur in the once mellow streets and trees of Los Osos. Some people will not give up quietly and keep asking uncomfortable questions.

Why hasn't the "Community Plan" proven itself worthy? Why have the backers of the "sewer in a park plan" come to another crucial vote?

Four residents of Los Osos think the CSD has done no wrong and has demonstrated "responsibility for solving problems." They write in a Tribune editorial today that "stopping the wastewater project does not solve our future problems."

Observers say the project needs redirection, not a halt. Take the park out of the sewer/wastewater treatment plant, and relocate them separately. Would you want your child playing 30 feet from serious microbial scrubbing?

This has cost the citizens of Los Osos (I used to be one!) too much time and money to get it wrong at this late date. "Might as well do it right, eh?" Borrowed money for this effort will always have to be repaid. So do it right, money is not the problem. Real leadership is the kind that is fair to all concerned and displays concern for the truth.

Leadership. Just where has the CSD's "problem solving" actually been demonstrated? Shutting out people from public meetings? Using bogus restraining orders against vocal critics? Threatening to cut down irreplaceable trees? Is the CSD avoiding "obstacles it did not create?" Click on that link and read a few more questions.

If you answer each point honestly--and yet you still want a park in a sewer and its massive cost--you just might get your wish when you vote. Just remember: you'll have to drink the water. --Newsstand Greg

Community Readerboard Sign Approved

2005-08-02T13:52:00.000-07:00

The Los Osos Community Readerboard sign gained approval this morning in a 5-0 vote of the County Board of Supervisors.

The supervisors were considering an appeal of an earlier planning commission decision allowing the sign to be built at the northwest corner of the intersection of Los Osos Valley Road and South Bay Boulevard.

Local resident and sign proponent, Gary Dove, argued in favor of building the sign and handed out illustrations of what the sign would look like when installed.

"The supervisors said good things about the sign, that it would be a benefit to the community," Dove said with a smile. "They also voted to refund our land use permit fee of $2257."

The action today concludes four years of planning and fund-raising work among residents of Los Osos to establish the Readerboard sign.

(Full disclosure: During my year as president of the Los Osos Rotary Club we concentrated on financing the sign project and gathering community support for it. --Newsstand Greg)

$3,000 Tree Benches And $200 Month Sewer Bills

2005-08-02T11:52:00.000-07:00

The price of the sewer for taxpayers, is being tracked by Ron Crawford, on his sewerwatch blog. At the time of the 1998 election that formed the Los Osos Community Services District, the monthly sewer bill for the county's project was estimated at about $60 - $75.

Future sewer bills in Los Osos are now estimated at over $200. per month, per household.

Ron writes (7/21/05): my favorite part about the most recent LOCSD cost estimates for the park at the sewer plant (picture below), besides, of course, the fact that a play field costs damn near $1 million, and a "Dog Park" is well over a half million dollars (who knew?), is that "Eucalyptus Benches" are $3,000 each. Now that's a nice bench. I wonder, will those benches be made from the same eucalyptus trees that need to be cut down to accommodate them?

And something else just occurred to me -- a Los Osos taxpayer that shot down Measure E-97 would have to pay that failed measure's tax for 300 years just to cover one "Eucalyptus Bench." Hmmm.

$2.3 million just for the park amenities, and that doesn't even include their operation and maintenance, estimated by local park professionals at another $3 million over the next 20 years.

Amazing. Just amazing.

The Mangling Of A Sewer Project

2005-07-27T21:20:00.000-07:00

by Ron Crawford, with permission from: sewerwatch.blogspot.com

No matter how the sewer issue finally plays out, one thing is for sure, the Los Osos Community Services District's clumsy handling of the project over the past six years will become legend in civics circles. To be honest, I already hear the snickering and snide remarks from knowledgeable government officials when I interview them on this subject.

But their reaction is understandable. Since the day the CSD took over the sewer project from the County, they have steered it straight into the wall, with a grand display of unimaginably poor decision making. They couldn't have handled the project worse.

To be accurate, because the majority of the first CSD Board was comprised of members of the Solution Group -- a 16-member community group that formed in 1997 to develop an ill-fated alternative sewer plan in Los Osos -- the sewer blundering actually began long before the establishment of the Los Osos Community Services District in November, 1998.

No, Solution Group... you do not get off that easy.

In 1997-98, through an aggressive and scrupulously questionable marketing campaign developed by Pandora Nash Karner, marketing director for the Solution Group and eventual number one vote-getter in the first CSD Board election, Los Osos voters were lured into believing that the "Community Plan" -- the name of the Solution Group's alternative sewer project -- was "better, cheaper, faster" than the county's project. Due to the slick and less-than-accurate marketing campaign, 87-percent of Los Osos voters buy in to the Solution Group hype and, in November 1998, overwhelmingly establish a Community Services District to take over the sewer project from the County and implement the Community Plan. Two previous attempts to establish a CSD in Los Osos failed.

However, little known at the time (and even to this day, surprisingly) was that the Community Plan relied on "risky" and virtually untested technology, and was simply not going to work in Los Osos. To complicate matters for the LOCSD and the Solution Group, several credible water quality professionals and studies confirmed that fact months before the 1998 election that established the CSD on a "better, cheaper, faster" platform. Members of the Solution Group, including Nash-Karner, worked closely with those water quality professionals throughout 1998 and were intimately familiar with the information.

For example, in the summer of 1998, an independent study known as the the Questa Study compared the Community Plan with the County's project. The study noted, among other things:

"It would be very risky and inappropriate to utilize the proposed (Community Plan's technology) for the Los Osos project - especially given the limited resources of the community."
"The County Plan provides far more assurance of the ability to correct the existing groundwater nitrate problem than is offered under the Community Plan."

Another credible example that demonstrates how unviable the Community Plan was, before the 1998 election, comes from California Coastal Commission staff member, Steve Monowitz. Monowitz, throughout 1998, crushes the Solution Group's project with prophetic accuracy in several reports including his department's own comparison of the Community Plan and the County's plan. Observations found in Monowitz's reports include:

"Pursuit of the Solution Group alternative also has the potential to result in significant delays to the implementation of a wastewater treatment project for the Los Osos area."
"(The Questa Study) also identified practical problems with the Solution Group treatment method that called into question the technical feasibility of this alternative."
"This analysis identified numerous project costs that had not been included in the Solution Group’s original estimations."
"The Solution Group Alternative poses greater economic risks."
"As currently proposed, the Solution Group alternative is inferior to the County project..."

Yet, despite a mountain of credible evidence that showed, months before the election that formed the CSD, the Community Plan -- a plan that relied on a "risky" series of ponds as a treatment process -- was not going to work in Los Osos, Nash-Karner, as marketing director for the Solution Group, in the run-up to the election, continued to aggressively publicize the deeply flawed plan as "better, cheaper, faster" with a "maximum monthly payment of $38.75."

According to the LOCSD, the future monthly sewer payment is now estimated at over $200.

The Solution Group marketing strategy included newsletters, bumper stickers, public presentations, numerous press releases, advertisements, posters, slogans like "Do-Doing it Right", "YES", and "Better, Cheaper, Faster", t-shirts, and more. The Solution Group would spend "hundreds of hours" and some $30,000 of their own money developing the unviable plan. Nash-Karner's husband, Gary Karner, who was also a prominent member of the Solution Group and is a landscape architect, called the local talk radio program, The Dave Congalton Show, last year, and admitted, on the air, that his wife placed a $700,000 bid to the LOCSD for public relation services after her first and only term on the CSD Board. She did not get the contract, according to Karner. At a recent LOCSD Board meeting, Nash-Karner said that her husband took a year off his job as a Cal Poly professor to work on the Solution Group's plan.

A credible source close to the story told SewerWatch recently that San Luis Obispo County staff, in mid-1998, prepared a long list of flaws in the Community Plan that were not being addressed by the Solution Group -- flaws that would have killed the project, according to the source. "This was stuff any developer would have to deal with," the source said. "(Former County Supervisor) Bud Laurent hand delivered that list to the Karner's, but they just sat on it."

Laurent, a long-time acquaintance of the Karners, told SewerWatch he doesn't recall the incident.

The CSD was established with 87-percent of the vote in November, 1998.

On March 4, 1999, the first CSD Board, comprised of three Solution Group members, Nash-Karner and current board members and recall targets, Gordon Hensley and Stan Gustafson, and two other like-minded members, unanimously voted to abandoned the County's viable, and nearly approved, project, and pursue the Community Plan, despite an overwhelming amount of evidence that clearly showed the plan was not viable in Los Osos.

Shortly after the CSD's decision to pursue the Community Plan, Executive Director of the Regional Water Quality Control Board, Roger Briggs, said the figures used by the LOCSD to compare the cost of its sewer project with the county’s project were "incorrect and very misleading." He added, "the County's project remains the most feasible and timely project." The RWQCB had also been extremely critical of the Community Plan before the election.

After nearly two years of delays and costs associated with pursuing the ill-fated and deeply flawed Community Plan, the CSD was forced to abandoned the project due to, among many other reasons, the lack of evidence that it would actually work. Both the Questa Study and Monowitz would prove to be amazingly accurate in their analysis of the Community Plan.

Information on the demise of the "Community Plan" is not forthcoming from the CSD.

On their web site, the LOCSD says:

"The following year (after the election in 1998 that formed the CSD), the LOCSD assumed responsibility for designing a wastewater treatment facility and the county plan was abandoned. After exhaustive technical study, consultation with engineers, health experts, regulators, residents and numerous public hearings the LOCSD chose a wastewater treatment facility believed to be the best option for the community."

That is not accurate.

According to reports submitted by the LOCSD in 1999, the deeply flawed and ill-fated Community Plan was originally selected as the sewer project of choice on March 4, 1999, just two months after the formation of the CSD.

Quietly, in late 2000, the CSD Board finally turned to a viable, yet more costly, sewage treatment technology, similar to what the County had proposed four years earlier.

However, when deciding where to build the dramatically redesigned treatment facility, the CSD Board, in yet another display of head-shakingly bad decision making, seemingly inexplicably identified a "strongly held community value" that the site of the sewer plant also double as a centrally located "recreational asset."

According to the LOCSD, “The size and location of the other sites did not provide an opportunity to create a community amenity. The (other potential sewer plant) sites on the outskirts of town, could not deliver a community use area that was readily accessible to the majority of residents." (Note: That quote is from the Facilities Report for the sewer project. The CSD does not have a .pdf file of the report for me to link to.)

All other potential sites on the outskirts of town were "rejected" on the basis that they did not accomplish the "project objective" of "centrally located community amenities."

The park element of the plan locked in the centrally located Tri-W location, and, due to its central location, multi-millions of dollars have to be added to the project for extra environmental, odor, and visual mitigation, on top of the cost of the multi-million dollar park amenities and their operation and maintenance.

Proponents of the current $151-million project contend that the "primary benefit" of locating the facility at the centrally located Tri-W site is that its central location will reduce energy costs associated with collecting the sewage. However, according to a CSD memo, the extra energy cost required to pump the sewage out of town would add only about $400,000 to the cost over the next twenty years. The estimated cost to maintain the park over the next 20 years is $3 million, on top of the park amenities themselves, now estimated at $2.3 million.

The five original CSD Board members were Rosemary Bowker, Stan Gustafson, Gordon Hensley, Pandora Nash-Karner and Sylvia Smith. Nash-Karner, Gustafson and Hensley, as well as former CSD Board members Frank Freiler and Bob Semonsen were members of the Solution Group, according to a Solution Group newsletter.

Gustafson and Hensley remain on the board today. They are facing a recall election in September.

- - - -

The LOCSD's Blundering Sewer Timeline
SewerWatch Style!

1997-98: The Solution Group, a 16-member community group established in 1997 to develop a deeply flawed alternative sewer project for Los Osos -- launches an aggressive, and scrupulously questionable marketing campaign for their alternative sewer plan. The Solution Group plan, known as the "Community Plan," is based on "risky" technology that the Solution Group insists is "better, cheaper, faster," will save "save $30 million," and be "drop dead gorgeous," when compared to the County's proposed (and nearly approved), project, despite ample information from several credible sources that corroborate the fact that the Community Plan is simply not going to work in Los Osos. Members of the Solution Group are intimately familiar with the information, yet their marketing director, Pandora Nash-Karner, continues to aggressively sell the deeply flawed plan to Los Osos as "better, cheaper, faster."

November, 1998: The Los Osos Community Services District, on a platform of "better, cheaper, faster" is established with 87-percent of the vote. The initial board consists of three Solution Group members, including number one vote-getter, and Solution Group marketing director, Pandora Nash-Karner. (Two prior attempts to form a CSD in Los Osos failed.)

1999-2000: The initial CSD Board, on March 4, 1999, unanimously votes to abandoned the County's viable sewer project and pursue the deeply flawed Community Plan, despite a large contingent of credible water quality professionals corroborating the fact that the plan is not going to work in Los Osos.

After nearly two years of delays and associated costs pursuing the Community Plan, the CSD realizes that the plan is not going to work in Los Osos and is forced to shelve the ill-conceived project for many of the same reasons that were mentioned years earlier by credible water quality professionals.

2000-01: The CSD finally (and quietly) turns to a technically viable project, similar to what the county was proposing four years earlier, but, seemingly inexplicably, the board also decides to include a multi-million dollar park in the project, despite almost non-existent community support to include a costly park in a very costly sewer project. The board, for no apparent reason, identifies a "project objective" that the site of the sewer plant also double as a "recreational asset" and contain "centrally located community amenities." The decision locks in the centrally located Tri-W site. All other potential sites on the outskirts of town are "rejected" on the basis that they do not accomplish the "project objective" of "centrally located community amenities."

2002-2004: The LOCSD pulls the park out of the plan almost entirely as a "cost saving measure."

2004: The California Coastal Commission tells the LOCSD that they can not move forward with the project without the amenities in the plan because the park facilities "factored into the previous decision to allow the treatment facility to be located on (the Tri-W) site, since other alternatives were rejected on the basis that they did not accomplish project objectives for centrally located community amenities."

The Los Osos CSD conducts a cost comparison study to see if there is "economic incentive" to relocate the sewer plant out of town. The analysis concludes: "There does not appear to be any economic incentive to relocate the WWTF from the Tri-W site to the Andre site." However, the comparison does not account for the now $2.3 million park included in the sewer project, or the estimated $3 million in operation and maintenance of the park for the next 20 years. If it had, it would have shown that multi-millions of dollars could have been saved by moving the facility out of town. The cost comparison study was completed almost at the exact time that the LOCSD votes to "reincorporate" the multi-million dollar park.

2004: Coastal Commissioner Dave Potter calls the Los Osos CSD's tactics "a little bait-and-switchy."

The CSD votes to "reincorporate" the now $2.3 million park, despite the fact that Los Osos voters have already voted that they do not want to be taxed $10 a year for public recreation in Los Osos.

Two "move the sewer" candidates, Lisa Shicker and Julie Tacker, are elected to the CSD Board by a wide margin.

Today: Due to the central location of the Tri-W site to accommodate the park, multi-millions of dollars have to be added to the project for extra environmental, visual and odor mitigation. That cost is on top of the estimated $5.3 million needed for the park and its maintenance.

The nearly two year delay resulting from the futile pursuit of the deeply flawed and ill-fated Community Plan adds millions of dollars to the cost of the project, and, very importantly, due to mounting time constraints, blows Los Osos' only chance of proposing an alternative to the current $151-million project.

More delays result, understandably, from irate Los Osos citizens angry over the very real possibility of $100-a-month sewer bills, and the false promise of the Solution Group's "better, cheaper, faster" sewer system.

At the time of the 1998 election that formed the Los Osos Community Services District, the monthly sewer bill for the county's project was estimated at about $60 - $75. Future sewer bills in Los Osos are now estimated at over $200. a month.

"Sewer Initiative" Off The Ballot?

2005-07-27T14:19:00.000-07:00

The latest court ruling yesterday may not allow the residents of Los Osos to vote on where their waste treament plant should be located. But a successful appeal tomorrow, Thursday (7/27), could reverse that decision. Stay tuned!

How A Park Got Into A Sewer

2005-07-26T14:47:00.000-07:00

In this space you'll read the latest reporting on the slow, yet fast-moving process of the contentious Los Osos Sewer project. You'll read material from former Bay Breeze editor, Ron Crawford (quoted with permission), and other official sources. Every effort will be made to attribute every "fact" to a credible source.

Full disclosure: I lived in Los Osos five years ago and know many of the players in this saga, on the LOCSD and in the neighborhood. I'm certain everyone wants what's best for the community. Yet it's almost as certain these events need the constant light of responsible media reporting to enable a better public understanding.

One simple question has refocused my attention on the sewer issue. Ron Crawford asked in his sewerwatch blog: How did a park get into the sewer in the first place? We're looking for real answers and better information.

When the public gets the unvarnished truth, it knows what actions to take. Here's a New Times recap of the action in the last few weeks. You are invited to send your fact-based reporting to this page editor through the CCNews Mission email address in the upper right corner of the page. You may also want to leave a comment; I'd like to know what you think.

Not On Our Dime

2005-07-26T14:38:00.000-07:00

reported by Ron Crawford.

According to a recent Tribune article, as much as $35 million in federal money could help pay for the proposed Los Osos sewer if an effort by Rep. Lois Capps, D-Santa Barbara, is successful.

No, no, no. Not on our dime.

Look, Los Osos, just because your CSD Board majority wants to throw your tax money at a multi-million dollar park that you have already voted that you do not want to pay for, and your Board majority can't answer why there's a park in your sewer project, doesn't mean that we should throw tax money at their mistakes too.

I mean, come on! An amphitheater in a sewer plant? And you want us to help pay for that?

Capps said recently that money for Los Osos' proposed $150 million sewer was authorized by a congressional subcommittee.

I'm going to take a wild guess here and say that the congressional subcommittee wasn't fully informed about the amphitheater, or the public restrooms, parking lot, dog park, community gardens, and everything else needed to accommodate the park, like the wave wall, and buried facilities, and odor scrubbing. $35 million? Sounds like Los Osos is going to need a lot more than that just for the park portion of their sewer project. And they want that to come from American taxpayers? Nice try.

Los Osos, you need a sewer, not a park. If your CSD Board can come up with a plan that includes a viable, bare-bones (translated: no park) treatment facility, then I'll argue that the Feds should pick-up at least half the cost. After all, they're picking up the tab for sewer projects in Iraq (I'm going to take another wild guess here and say that NONE of those systems include an amphitheater). But until then, I argue that the $35 million would be better spent elsewhere, like on the families of the service men and women that have been killed in Iraq.

"It's not a hard and fast guarantee," Capps spokeswoman Shannon Lohrmann said about the Federal funding. "But this is a great first step." For the sake of American taxpayers, let's hope it's the only step... at least for this flawed project.

'til next time. (article quoted by permission of the author.)

Tangled Web

2005-07-25T15:03:00.000-07:00

reported by Ron Crawford.

According to the Value Engineering process conducted by the LOCSD's engineering firm, Montgomery, Watson, Harza, there could be significant cost-savings in the project if the "site amenities" (a.k.a. park) were removed. Yea. No kidding. In fact, multi-millions of dollars could be saved if the park was removed, but the problem is, according to the District's Coastal Development Permit (CDP), the CSD is not allowed to take the park out of the project. Apparently, someone needs to tell MWH about Special Conditions 12 and 17. Those are two of the many conditions that the California Coastal Commission made the LOCSD agree to before the CCC issued the CDP last August.

I love Special Conditions 12 and 17. They say, in no uncertain terms, that the park is not up for negotiation. Why? Because the only reason the CCC caved on the Tri-W site in 2002 (the agency doesn't like the idea of the facility at Tri-W... too much environmentally sensitive stuff), and agreed to amend the Local Coastal Plan (LCP) to allow the facility at Tri-W, was the "project objective" of "centrally located amenities." And in 2002, the LOCSD's site plan included all kinds of pretty "amenities" like "community gardens" and an amphitheater (that's right... for all you new-comers, the Los Osos CSD is putting an amphitheater in their sewer plant... I'm not making that up.)

So, imagine the surprise of the CCC when the LOCSD showed up two years later with a revised plan that was inexplicably missing all of that pretty stuff.

To me, the chronology of the park in the plan is amazing:
In 2002, the CSD says to the California Coastal Commission that the sewer plant has to be located at Tri-W because it's the only site that accomplishes the "project objective" of a "centrally located" park. The CCC reluctantly agrees, and goes through the laborious task of amending the Local Coastal Plan to accommodate the facility at Tri-W. Then, as a "cost-saving measure," the CSD yanks the park out of the plan almost entirely, then, when it comes time to go back to the CCC to get the development permit in 2004, the Los Osos CSD shows up with a park-less plan, and that left the Commissioners (and their staff) scratching their collective head... what happened to the friggin' park?

Wow.

The 2004 California Coastal Commission, understandably, was not amused by the Los Osos CSD's act, and in a strikingly harsh, yet warranted, move, told the CSD that they could not move forward with their sewer project unless the public park -- the same public park that the CSD originally presented to the Commission, the same public park that is dictating the "downtown" location -- was put back into the plan, and maintained "in perpetuity." Then (and in a great moment of bureaucratic smack) Commissioner Potter called the CSD "a little bait-and-switchy" (I still love that quote).

At a recent Los Osos CSD meeting, director Richard LeGros said that the process involved with developing the sewer was "followed to a T."

Well, I suppose my question to Mr. LeGros is this: If the Los Osos CSD followed the sewer development process "To a T," then why did a Coastal Commissioner refer to the way the Los Osos CSD followed the sewer development process as "bait-and-switchy?" Something doesn't add up.

I'll tell ya, the Los Osos CSD is lucky I wasn't a member of the California Coastal Commission in 2004 when they were applying for their CDP.

I wouldn't have made them "reincorporate" the park. No, my response would have been more along these lines:

"For God's sake, two years ago, we went through that entire amendment process (LCP Amendment 3-01) so you could accommodate your "centrally located" amenities in your sewer, and now you come back at us with a plan without the "centrally located" amenities? Are you playing with us? Who do you think you're messing with? We're the California Coastal Commission! Stop wasting our time! You know what? Since you guys are in the mood to pull your "centrally located" amenities, then we're now in the mood to pull your development permit. You don't want a park now? Then start the hell over. Go back to the damn drawing board. Oh, and by the way -- Regional Water Quality Control Board -- feel free to start fining the Los Osos CSD anytime you feel like it."

That would have been my reasonable, appropriate and understandable response.

Source stuff... The following is from the August, 2004, California Coastal Commission staff report, page 89:

"... the LOCSD has agreed to reincorporate public amenities that were included in the site plan reviewed by the Commission during the processing of LCP Amendment 3-01 but later removed by the LOCSD as a cost saving measure. These facilities, which include a 15 space public parking lot and drop off area, an amphitheater, community gardens, restroom, tot-lot, and picnic areas, factored into the previous decision to allow the treatment facility to be located on this site, since other alternatives were rejected on the basis that they did not accomplish project objectives for centrally located community amenities. Therefore, providing these facilities as part of the project, as required by Special conditions 12 and 17, is necessary to fulfill commitments to provide enhanced access and recreation opportunities that were made during the processing of LCP Amendment 3-01.

'til next time... (article quoted by permission of the author.)