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Home My WebLink About03/25/1997, 1 - COMMENTS OF FINAL EIR, WATER REUSE PROJECT (SCH NO. 92031048). `ep%Tal Cower J. .o CENTRAL COAST SALMON ENHANCEMENT, INC. \-mo0 FISH FOR EVERYONE a non-profit corporation o \ oroo o .ec l�oda ceia March 25, 1997 Mr. Dave Pierce Utilities Department 1 City of San Luis Obispo 955 Morro Street San Luis Obispo, CA 93401 RE: Comments on Final EIR, Water Reuse Project (SCH No. 92031048). Dear Mr. Pierce, San Luis Obispo Creek has a rich history of trout fishing. In a book by Rose MdCeen (1988), she writes that as recently as the early 1930s, during the Depression years, "if one had nothing else for dinner, there were always the fish in San Luis Obispo Creek. During those disastrous years, the creek literally fed many people, just as it had once fed the Mission Padres and the Chumash Indians." During this time and for many years to follow, the trout population declined. One of the well documented contributions to this decline is the city's wastewater effluent that is discharged into the lower seven miles of the creek. Since at least the 1940's, forty percent of San Luis Obispo Creek has been made inhospitable to trout by raw sewage, chlorinated sewage, or un-ionized ammonia. Today we have dean water discharging from the wastewater facility. For the first time in thirty-five years of fish surveys, we are seeing trout in the lower creek We are excited to see this. Now the city proposes to reduce the discharge of this clean water by sixty-nine percent. Studies commissioned by the city clearly show that this level of reduction will produce significant impacts to the trout. P.O. BOX 277 • AVILA BEACH CALIFORNIA 93424 Mr.Dave Pierce March 25, 1%7 Page 2 In our January 1996 letter we outlined our concerns for this level of reduction. The responses to our comments on the draft report are unacceptable. Similarly, the mitigation plan proposed in the final report is unacceptable and will not reduce impacts on Steelhead Trout to a level of less than significant. While city studies can quantify impacts to the creek, they cannot quantify the benefits of mitigation. This creates too large of a risk when the life of an entire fish population may be at stake. The Department of Fish and Game, in 1996, published a Steelhead Restoration and Management Plan for California. This plan specifically identifies the importance of southern Steelhead and the need to maintain adequate stream flows for their survival. Based on this finding as well as findings of the instream flow study, biological assessment, and our trout habitat inventory, we maintain our support for this project with a forty-five percent reduction in effluent as opposed to a sixty-nine percent reduction. Finally, in discussion with the National Marine Fisheries Service, Department of Fish and Game, and California Sportfishing Protection Alliance, there is consistent and substantial concerns regarding this project. While we do not look forward to taking this project to protest at the State Water Board, certification of this final environmental impact report will leave no other options. Our organization has participated in and supported the goals of this water reuse project since it began. We continue to offer our services in good faith and spirit. Please contact us if we may provide clarification or additional comment. Respectfully Submitted, laul ve an Project Manager/Certified Fisheries Scientist 805/773-6769 (office) 805/773-6942 (fax) salmonfix@aol.com (email) EIR CERTIFICATION �►� • Introduction tel� eG� • Project Description a • v • Environmental Overview Y ' • Impacts & Mitigations • Findings a 7 RECYCLED WATER t ` wAMR uaeP 2n ALLOCATION �Y.Ph c.rtnm PMP DO f LP ........................ .............................. Pr.P..•P .S iiR uM I00 MPYP 9p \ SNwb 1]0 700 Existing 455 Future 0 •_ p•L vm..r, FPp YY Gp YF Ln Li 4q 9p ON Nw 0.[ PI.M1NP �`f 7200 Minimum Pune 90Wn.r DEDICATED WATER RECLAIMED WATER 1.7 CFS Classifications • California Water Code > Disinfected Tertiary Reclaimed Water • Creates Water Right =;> Disinfected Tertiary Reclaimed Water-5 NTU • First Voluntary > Disinfected Secondary-2.2 Reclaimed Water > Disinfected Secondary-23 Reclaimed Water > Undislnfected Secondary Reclaimed Water b b RECLAIMED WATER USES RECLAIMED WATER Disinfected Tertiary Reclaimed Water-5 NTU PRIORITIES Irrigation • Category 1 J Food crops-water contacts the edible portion J Parks,playgrounds&school yards —New Development J Residential landscaping —Existing Uses of City Water J Un-restricted Access Golf Courses —Existing Uses Within URL Other —Creek-Existing Instream Uses J Flushing toilets and urinals Category 2 J Industrial process water that may contact worker J Commercial laundries —Outside URL Uses for Agriculture or J Artificial snowmaking Open Space Td Decorative Fountain PROJECT SCHEDULE .21. ao vuv. no vn.•. w 8tn.•Y t]0 State Board Hearing Spring 1997 _ Award Design Contract Spring 1997 Award Construction Contract Spring 1998 Deliver Water Summer 1999 EIR CERTIFICATION ENVIRONMENTAL OVERVIEW • Introduction -Water Resources -Utilities • Project Description -Biological Resources -Public Services&Recreation -Public Health -Noise • Environmental Overview -Geology -Light BGlare • Impacts & Mitigations -Air Quality Cultural Resources -Transportation Growth Inducement • Findings -Land Use -irreversible Use of Resources -Aesthetics Cumulative Impacts b 2 ENVIRONMENTAL EIR CERTIFICATION STUDIES • • Instream Flow Study Introduction • Hydrology and Groundwater • Project Description Modeling • Environmental Overview • Biological Resource Assessment • Impacts & Mitigations and Impact Analysis • Findings aWINe POTENTIALLY IMPACT SIGNIFICANT IMPACTS Reduced Flow in creek Reduced Flow in Creek MITIGATION • Steelhead DEDICATE 1.7 CFS • Southwestern Pond Turtle -Move WRF Release Point • Tidewater Goby -Well Field IMPACT IMPACT Tidewater Goby N'; Pond Turtle MITIGATIONMITIGATION DEDICATE 1.7 CFS DEDICATE 1.7 CFS • Creek Management • Create Deep Pool Habitat 7 a 3 IMPACT MITIGATION MEASURES Steelhead "`'�--7- f DEDICATE 1.7 CFS MITIGATION • Improve Fish Passage DEDICATE 1.7 CFS • Create Deep Pool Habitat • Improve Fish Passage • Move WRF Release Point • Move WRF Release Point • Well Field • Well Field • Creek Management • Creek Management 'h1 g�1, REQUIRED ACTIONS EIR CERTIFICATION Dedicate Discharge City Council Establish Fee/Acre-Foot City Council • Introduction Biological Opinion NMFS • Project Description Issue Permit SWRCB • Environmental Overview Award Design City Council Loan Application City Council Impacts 8 Mitigations Loan Approval JSWRCB • Findings b b 4