More Evidence Shows That Additional Analysis of the Tri-W Project is a Waste

County staff needs to dig a little deeper. They're not getting to the nut.

In the staff report for the Los Osos item on today's Board of Supervisors meeting, it discusses why one of the many "protests" to the recent 218 vote isn't a valid protest. This particular protest argues that the mid-town-sewer-plant Tri-W project is still considered a "viable project alternative" by county officials, and that somehow tainted the 218 process. The report counters the protest with this:

"Since the Tri-W project has proven to be a viable project objective by receiving permits, funding and broke ground, it would be inappropriate to remove it from consideration prior to the environmental review process."

However, what they are missing there -- and this is great... because it's key -- is that every single one of those permits that they mention, was based on a "project objective for centrally located community amenities," as I've reported on, repeatedly, over the past three years.

The perfect example of that comes from the staff of the California Coastal Commission, where, in the Tri-W Coastal Development Permit (CDP), it reads:

"... other alternatives (to the Tri-W site) were rejected (by the LOCSD) on the basis that they did not accomplish project objectives for centrally located community amenities."

On June 21, 2005, I sent then-CSD General Manager, Bruce Buel, an e-mail containing these two questions:

1) What would be the rationale for siting the treatment facility at Tri-W if the "project objective" of "centrally located amenities" was not in the project?

2) Why are "centrally located amenities" a "project objective?"

Buel never replied, of course.

So, look what's happening now, today... this is great: The only way Tri-W was "proven to be a viable project," and therefore retain all of its permits in the first place, was because of the initial Los Osos CSD's "project objective for centrally located community amenities."

However, county officials, in recent documents, have already said they will not develop that same project objective (and, I find it shocking that a county official actually has to say something like: "Na... we will not be including a picnic area and an amphitheater in our sewer plant." Wow, it's come to that, huh?) However, without that project objective, every single Tri-W permit -- its EIR certification, its CDP -- instantly becomes baseless.

So, when county staff now writes, "Since the Tri-W project has proven to be a viable project objective by receiving permits, funding and broke ground, it would be inappropriate to remove it from consideration prior to the environmental review process," that statement is also baseless.

Without the "project objective for centrally located community amenities," the Tri-W project was NEVER proven to be a viable project, and the county ain't developin' a "project objective for centrally located community amenities," which means the county is throwing money and time at a project that, sans a "project objective for centrally located community amenities," was never shown to be permitable.

In the aforementioned staff report, it reads:

"... each project -- including Tri-W -- will have numerous reviews..."

I wonder what the ballpark cost estimate is for the "numerous reviews" that will take place in 2008 for a "project objective for centrally located community amenities"-less Tri-W project?

Thousands? Tens of thousands? Hundreds of thousands? Millions?

I'd ask county officials that question, but I already know they'll never answer it.

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Current LOCSD Director, Lisa Schicker, recently wrote a "Viewpoint" where she also argues (with very good arguments... they sound familiar ; - ) that more analysis of the Tri-W project is a complete waste. It's posted on Ann Calhoun's great blog: here.

County's Environmental Analysis for Los Osos Potentially Redundant

Below's my latest question to county officials that, to date, remains unanswered. I sent it on 12/04/07, to environmental specialist, Mark Hutchinson (and cc'd it to several other official county types).

I'm posting it here because, 1) it's a great question (which means, of course, county officials will never answer it... and that's too bad, because the answer could potentially save a heck of a lot of time and money), and; 2) if you think it through, not only is it an excellent question, it's hilarious, as well... because it's so true!:

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Hello Mark,

I have a couple of quick questions, please, regarding the "public scoping meeting for the Los Osos Wastewater project’s Environmental Impact Report,” Tuesday, December 18":

Section 15093(b) of the CEQA Guidelines specifically provides that "a statement of overriding considerations shall be supported by substantial evidence in the record," and since I recently reported at sewerwatch.blogspot.com that the 2001 LOCSD's statement of overriding considerations was not "supported by substantial evidence in the record," then why wouldn't almost all of the 2001 EIR suffice today?

See what I mean there?

As long as it's not needlessly overridden, like it was, shouldn't about 90-percent of the 2001 EIR be useable today?

And, I've heard LOCSD Directors Schicker and Tacker say, numerous times over the past three years, that the 2001 EIR concluded, before it was overridden for no reason whatsoever, that an out-of-town site, with STEP/STEG technology would be the most "environmentally preferable" way to go.

Since there is no substantial evidence in the record on why the 2001 EIR was overridden in the first place, doesn't that mean that the original EIR, or a large portion of it, would suffice today, and then all that would be needed to comply with CEQA would be some sort of supplement detailing the out-of-town sites under analysis, like the Giacomazzi site, that are, all of a sudden, now "feasible?"

It seems to me that "public scoping for the Los Osos Wastewater project’s Environmental Impact Report" is about 90-percent redundant?

If that's not accurate, please tell me how I'm wrong. Unlike most, I love hearing that, because I learn from it.

Thank you,
Ron
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Hutchinson's response to that excellent question that could potentially save months, if not years of expensive, redundant environmental analysis?

" ."

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