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March 2002

Damning Report On Pt. Reyes EAH Housing Sewage

By Louis Nuyens

The Ecumenical Association for Housing's (EAH) Point Reyes Station project proposal has been fraught with controversy, both in terms of its overall impact on the town, and in terms of its technical execution.

A recent report, from an independent engineering firm commissioned by a group of west Marin residents, supports concerns raised since the EAH project was first suggested, that the suitability of the site for the project design has not been adequately demonstrated.

The site for the project's single family homes, 27 apartments, a farm property (including 2 additional residences), and a site for commercial use to be determined at a later time, is a sloped, agricultural parcel of 19.3 acres, long-known to exhibit sheet flow during typical wet seasons. Long-time residents of the town raised concerns early on, that the site's hydrology and geology might lead to surfacing of untreated or under-treated effluent from the project's septic systems.

On 28 January 2002, Peter Haase, Principal Engineer with Fall Creek Engineering, Inc. (FCE), issued a report critical of numerous aspects of the Final Environmental Impact Report (FEIR) and hydrological data and analysis by project consultants Questa Engineering, Inc.

The FCE report concluded that, "The FEIR does not demonstrate that there [is] sufficient "storage capacity" in the unsaturated soils (vadose zone) to "prevent untreated or partially treated sewage effluent from surfacing during average and wet water year conditions." It also concluded that the FEIR did not adequately address, "potential water quality impacts to the North Marin Water District [(NMWD)] water supply wells and Lagunitas Creek, onsite and cumulative impacts to groundwater and surface water quality from additional nitrates from the proposed wastewater systems. [and] cumulative impacts to surface water from potential impact from plan stormwater runoff and erosion."

The septic systems proposed in the project rely on in ground leachfields which must stay 3 feet above the groundwater level at all times, as specified by the Regional Water Quality Control Board's San Francisco Bay Basin Plan. The effluent is treated while residing in the soil more or less near the ground surface, a process which depends on adequate "soil conductivity" of water downward through the soil. If, during a storm event, groundwater levels rise too much, effluent could be carried to the surface on the site, and flow down-slope, which in the case of this parcel, would be into the downtown area of Point Reyes Station, and into Lagunitas Creek. Undertreated effluent could also be transported underground and emerge off-site.

Haase's FCE report notes the project, "will add a significant volume of wastewater and stormwater to this area, which already experiences shallow groundwater conditions." As a preliminary point of study, Haase honed in on the lower part of the site, on which both apartments and houses would be built, where groundwater levels commonly rise to 3 to 6 feet from the ground surface. FCE calculations conclude that, "Under average and wet rainfall years shallow water could cause untreated or partially treated wastewater to surface at or down-slope of the site, posing a significant threat to public health and the environment." It should be noted that various aspects of project design might also reduce soil conductivity, effectively raising groundwater levels still further.

The report goes on to point out other potential risks, including to NMWD water supply wells and Lagunitas Creek, and to criticize numerous assumptions made by Questa without theoretical or sufficient factual justification, such as failing to address all sources of runoff onto the site.

In response to the FCE report, Questa fired back a strongly-worded point-by-point reply, saying, largely, that Fall Creek's analysis was flawed in that it relied on incomplete information. Questa rebutted with the claim that many of Fall Creeks concerns were addressed by an earlier, "On-Site Sewage Disposal Feasibility Report, February 2000" the details of which were not included in the FEIR, but which had been referenced in the FEIR, and therefore, according to Questa, incorporated by reference. As Haase was out of the country at the time of Questa's rebuttal, the FCE response to Questa's comments were made by Dr. Richard Armstrong, Ph.D., Principal Engineer with Fall Creek.

Typically all details specific to a project for which an EIR is required appear in the EIR document, thereby enabling comprehensive analysis of the project. Moreover, the Feasibility Report was not readily accessible when initial inquiries for it were made. Elena Belsky, an environmental investigator, tracked down a copy and made it available to Dr. Armstrong. Dr. Armstrong was therefore able to address the document that Questa claimed would justify Questa's assertions.

Rather than find cause to retract statements made by Haase, Armstrong concluded that Haase's points remain valid, that the data and assumptions in the Questa Feasibility Report, like those in the FEIR, were inadequate to predict the success of the project's wastewater and stormwater systems design.

Further, terming the Feasibility Report, "erroneous on its own terms," Armstong found inconsistencies in Questa's representation of data gathered at the site and used by Questa in analysis calculations.

The most striking discrepancy relates to soil conductivity (of water downward through the soil). Questa used a figure equivalent to 20 feet per day (fpd) for the area investigated, saying actual measurements averaged closer to 24 fpd. Armstrong's analysis found that test results actually averaged approximately 7.2 fpd. Armstrong pointed out that Questa, if it had used accurate numbers in the "mound analysis" used in Questa's Feasibility Report, would have been forced to conclude that, "none of the leachfields mentioned here will meet the required separations from groundwater." Armstrong suggested that Questa go back to the drawing board, perhaps employing a more sophisticated modeling method.

A peer review of the EIR, by Psomas Engineering, discovered similar discrepancies, and noted that the 20 fpd used by Questa was a preliminary estimate, and that the number was actually closer to 9fpd averaged over the entire site. Yet no recommendation to update the Groundwater Mounding study was suggested by Psomas. Fall Creek's review was directed toward what is believed to be the most problematic area on the parcel, the northernmost, lower housing development and apartment complex, where FCE averaged the conductivity data for that area only, and came up with 7.2 fpd.

It should be noted that the Fall Creek's reports were preliminary and do not explicitly state that the current project design cannot work, but, rather, that the FEIR and analyses by Questa are not sufficient to prove that it can work. The report does, however, point to many indications that show likelihood that the current design will not work, and that it might pose significant risks to public health and the environment.

The Fall Creek report was commissioned by Elena Belsky, Mark Warner and John Sharp, a number of Point Reyes Station residents, and Tomales Bay Association, who felt that concerns voiced regarding the site's hydrology had been unwisely passed over, and that impartial, independent scientific analysis was needed to lay to rest or support the site-related concerns that had been raised.

Although the Fall Creek report was submitted to the Board of Supervisors before the decision, the Board approved the FEIR on January 29. Although the EAH project has been in the public eye for several years, and although the FEIR has been approved by the Board of Supervisors, project approvals have not yet been granted: the Master Plan, Precise Development Plan, Coastal Permit, and various rezoning of the property, are slated for Board of Supervisor's approval in mid-March. In light of the Fall Creek report, the County Planning Commission concurred that there are remaining concerns over water quality, and acknowledged the Fall Creek report's criticisms by requiring County Environmental Health Services to address those points as a condition of the Commission's recommendation of approval to the Board of Supervisors.

However, the Planning Commission's decision to recommend approval or denial is simply that: a recommendation; the final decision is in the hands of the Board of Supervisors.

The residents of Point Reyes Station and greater west Marin have been approximately evenly divided over the relative merits of the project, which would bring a mix of affordable housing, market rate housing and commercial development, while increasing the population of Point Reyes Station by 25% in one fell swoop. Although the project is within the limits of the Point Reyes Station community plan, the project as currently designed would also set several precedents that could make large west Marin developments more likely.

Regardless of the theoretical benefits of the project, questions have been raised which should be thoroughly resolved before any approvals or entitlements are given for the proposed project on the proposed site. To do otherwise would be a mistake that might bring long-term environmental and public health consequences.

 

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