Counterpoint to Cambrians for Water (C4H2O) Position Statements

C4H2O Statement 1: C4H2O’s objective is water security, not population growth

PROTECTCambria Counterpoint:

C4H2O has steadfastly supported adding additional water connections, and additional residential and commercial development. 

The current project description for the WRF states that adequate water can be supplied for 4650 total residential water connections, so that means at least 650 new residential water connections over 20 years. At over 30 new residences a year, plus additional commercial and affordable housing, that is major growth in a town of 6000. 

It should be noted that 30% of the waitlist is made up of current homeowners, and first construction will take place in the most heavily forested areas. There is no provision of additional water for firefighting, so a build-out without additional water for fire suppression is simply dangerous and reckless. 

Because of limited water capacity, adding additional connections actually reduces long-term water security.

C4H2O Statement 2: The WRF is cost effective

PROTECTCambria Counterpoint:

The total expenditure for water and WRF in the 2020/2021 budget is $4,033,090. For 530 acre-feet of total estimated annual water production, the cost per acre-foot is $7610.  The budget numbers include WRF operating costs, up to the dollar amount in the operating reserve account, currently $353,000.

C4H2O currently supports running up to nine daily round trips of diesel trucking to a licensed waste disposal facility many miles from Cambria, to dump hundreds of thousands of gallons of concentrated Reverse Osmosis (RO) wastewater into the ocean. Where is this money going to come from? 

The C4H2O website states that the WRF will add “about $20 per month” to our water bills. Based on the average WRF expenditures over the past few years, the actual amount is over $30 per month, a time period in which the WRF has not operated. 

Add in the costs for the electricity to operate the energy-intensive RO system, the costs to pump hundreds of thousands of tons of water from the plant to the injection well, and the cost of RO wastewater disposal, and the actual costs to Cambria ratepayers will be much higher. Cost effective for whom?

This emergency water project was initially proposed at $1.5 million for portable units then became an $11 million permanent plant, with total costs to date estimated at $18 million. There seems no end in sight for expenditures and there is no scenario where the WRF is cost effective. 

C4H2O Statement 3: The WRF and the environment

PROTECTCambria Counterpoint:

If the facility were operated at the output levels stated in the project description, the aquifer would be contaminated by saltwater intrusion. This would cause adverse water supply and environmental habitat impacts. Operation at stated output levels would also violate water agreements with adjacent landowners.

C4H2O Statement 4: Using the WRF for Long-Term Water Security was not Bait and Switch

PROTECTCambria Counterpoint:

Changing the permit application to allow hundreds of new additional customers was the Bait and Switch. Because of limited water capacity, adding additional connections actually reduces long-term water security.

Cambrians did not agree to a growth-inducing WRF. The project we were asked to support through that rate increase, was an Emergency Water Supply project for current residents when the District declared a Stage 3 Water Shortage Emergency.

Here is the actual language from the CCSD’s June 6, Project:  2014  Notice of Proposed Increase in Water Rates to Fund an Emergency Water Supply Project: The increase in water rates is intended to fund the cost of an Emergency Water Supply Project. Because projected water demands could exceed available supplies from the Santa Rosa and San Simeon Creek aquifers (Cambria’s only water supply sources), the CCSD has determined that an Emergency Water Supply Project is vital to ensure the security of Cambria’s water supply during the upcoming dry season. On May 15, 2014, San Luis Obispo County issued an emergency permit to the CCSD for the construction and operation of an Emergency Water Supply Project to serve existing customers within the CCSD’s service area.

Here is the language from the Project Description from CCSD’s 2020 Coastal Development Permit application: “The water supply augmentation goal of 250 AFY was determined to meet the minimum capacity necessary to improve water supply reliability to serve approximately 4,650 residential units (including both existing connections and CCSD-approved wait list customers).”

No specific referendum or board action on the change has ever happened. Cambria ratepayers understand this.

C4H2O Statement 5: The WRF is capable of producing clean, safe, potable water

PROTECTCambria Counterpoint:

Maybe – but not enough additional water for hundreds of new customers or for providing a water supply for firefighting. Why should Cambrians pay for manufacturing such expensive water when it’s unnecessary outside of Stage Three drought conditions? 

Cambrians voted for CCSD Board candidates who championed an EWS back in 2014 to serve existing ratepayers, not for growth purposes.

At a recent NCAC meeting to consider the project the chair dismissed public comment and letters clearly confirming that the majority of respondents still do not want this machine used for growth. 

C4H2O Statement 6: CCSD’s pending application for a regular operating permit should not be delayed to complete additional technical environmental studies

PROTECTCambria Counterpoint:

The current application for a (regular) operating permit for a WRF is not pending. Required by the County and Coastal Commission since at least 2017, it remains mostly incomplete after nearly four years.

There are no “new” or “additional” technical environmental studies required. The County and other permitting authorities required these studies back in 2014! 

Adding hundreds of new connections without enough water to provide water security to the community in a drought will lead to serious water shortages in the future. If too many new connections are added, costly modifications or additions to the facility will be needed in the future to provide water security for the community. 

Due diligence has not been a rigorous part of CCSD’s process since 2014. The Coastal Commission has requested streamflow studies and other documentation for years, which have never been provided and are essential to understanding the system’s impact on the local environment. 

According to the C4H2O website, it appears that your group holds concerned citizens responsible for delays to this process. We would suggest that CCSD, not any “opponents” has been entirely responsible for the following outcomes:

1. Construction of a poorly designed RO wastewater evaporation system a half mile from the ocean, which has failed, resulting in a $3 million CSD lawsuit against the manufacturer The evaporation pond supposedly designed for a 1000 year flood/rain event that failed in four years and earned CCSD a cease and desist order, only removed when the pit was emptied. 

2. Selecting a location in an environmentally sensitive habitat area (ESHA)

3. Lack of required reporting that resulted in a $600k Regional Water Board fine (which, thankfully, was reduced to $60k by the Water Board)

4. Adjacent landowners prepared to go to court if CCSD overdrafts and infringes on their senior water rights

5. An “information hold” on the current incomplete CCSD application to San Luis Obispo County for a “regular” Coastal Development Permit CDP application which includes nine pages of questions and requests for additional data. The majority of the additional data requested was included in the county’s response to CCSD’s also-incomplete 2014 CDP application, which was subsequently withdrawn.