HomeMy WebLinkAbout01/14/2020 Item 05, Greening
Wilbanks, Megan
From:Eric Greening <dancingsilverowl@gmail.com>
Sent:Tuesday, January
To:E-mail Council Website; environmentalplanning@calpoly.edu
Subject:MAJOR inconsistency between SLO City Water Resources Status
Report and Cal Poly Master Plan RDEIR
Hello!
This letter is intended to be part of the record of comments on the Cal Poly Master Plan RDEIR (as a
comment by Eric Greening), and ALSO to be in the record for the San Luis Obispo City Council meeting of
January 14th, 2020, relative to the item in which the City's 2019 Water Resources Status Report is being
received and taken into the record. The reason for this unconventional juxtaposition of recipients and
purposes is the urgency of getting the City and Cal Poly on the SAME PAGE relative to the critical issue of
water supply before a rushed culmination of the Master Plan's long CEQA process causes yet another
Draft Environmental Impact Report to be unable to move forward to a Final.
Here is language from the Cal Poly Master Plan RDEIR: "Impact 3.14-1: Require or Result in the
Relocation of Construction of New or Expanded Water Infrastructure"
"Implementation of the 2035 Master Plan would increase the volume of potable water conveyed
through the existing City connections. Modeling indicates that there is adequate conveyance capacity to
accommodate anticipated development associated with the 2035 Master Plan under average day
demand, peak daily demand, and peak hourly demand. New campus development would require
connections to water supply pipelines. Because the campus already contains substantial pipelines and
water delivery infrastructure, construction of additional infrastructure to connect new academic
buildings, student housing, and other development to the existing system is expected to be minor,
consisting of relatively sort pipeline connections in the existing delivery pipeline. Thus, the impact
would be LESS THAN SIGNIFICANT."
Now, a quote from the City's 2019 Water Resources Status Report: "At a March 2019 study session, City
Council provided direction to staff related to short term water sales. A potential recipient of this
program may be Cal Poly while the university secures a permanent water supply specifically related to
housing production. Council supported broadening existing policy language for the City to supply non-
potable water (raw water or recycled water) through a short-term agreement for agricultural
purposes. Short-term agreements would be crafted to include provisions for service interruptions or
reduction, due to operational issues or climatic events, low reservoir levels, increased water demand
forecasting, or water quality deterioration. Meaning, during a water shortage emergency, City water
deliveries would be prioritized above those included in a short-term sales agreement."
The RDEIR is premised on Cal Poly's City connection providing all the water needed for residential and
academic use, with minor connections to individual buildings constituting the only "New or Expanded
Water Infrastructure." The City's understanding is that for POTABLE use in new campus housing and
other buildings, Cal Poly would be responsible for finding a PERMANENT source, which is NOT the City of
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SLO; the City will PERHAPS provide non-potable water on a temporary basis, and not reliably. I have
been searching the RDEIR in vain for any indication of what this "permanent" source would be, or how it
would be brought in without the need for "New or Expanded Water Infrastructure." I am aware that Cal
Poly has been searching; late last year, an agenda item at the Morro Bay City Council discussed
negotiations over the sale of some of Morro Bay's not-too-abundant water supply to Cal Poly, but no
contract was signed; their Council simply directed that negotiations can continue. Morro Bay's public
works people won't know if they have water to sell until they understand the operational constraints
and opportunities involved with their yet-to-be-built new Wastewater Treatment Plant, for which
ground has yet to be broken.
Clearly, given the incompatible parallel universes described in the City and Cal Poly documents, it is
critical that the City and Cal Poly immediately do what they can to get on the same page. Until this
happens, it is foolhardy for Cal Poly to plan on ending the comment period on the RDEIR on February
3rd, less than a month after the campus community has re-inhabited the campus, and with this vital
issue unresolved. The City should request an extension of the comment period, and Cal Poly should
honor it; if yet another recirculation is to be avoided, the comment period will need to be left open long
enough for the City and Cal Poly to get on the same page relative to the make-it-or-break-it issue of
water supply, to somehow make available to the public new supplemental information that embodies
that common understanding and analyzes its impacts, extending an adequate comment period for the
entire document that clearly INCLUDES that supplemental information and clarifies what obsolete
information is being replaced, before the comment period on the entire RDEIR closes.
I have not had time to go into depth with the entire RDEIR, so I can't yet indicate whether, in subject
areas other than water supply, there are similarly serious inconsistencies that would prevent moving
forward to a Final EIR, but to give the public adequate time to uncover these, it is absolutely essential
that the comment period be extended well beyond February 3rd, and that the RDEIR be closely
scrutinized by the City and all other interested parties so that anything else that needs similar action can
be caught and acted on.
Many thanks, Eric Greening
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