The City Council recently voted to authorize a contract to perform a mitigated negative declaration for its sewage treatment/reclamation plant on the golf course. It will be using up almost all of the rest of the $800,000 already budgeted for this project (not including the $4 million separately authorized to connect the sewage line from the Navy Coastal Campus to the City, principally to have enough sewage to make the plant feasible). Before voting, Council heard that of the 27 other municipalities which had proposed the same project, all realized that they were legally obligated to perform a complete Environmental Impact Report (EIR) in order to be compliant with California’s environmental law, CEQA.
Without identifying a single site-specific reason exempting Coronado from complying, Council voted to proceed without doing a full environmental analysis. Amazingly, the City Manager replied that it is common for a City to be sued if it does a negative declaration, and common to be sued if it does an EIR, so why spend money on doing the full analysis to comply with the law. Implicitly the City concluded that it had no significant environmental concerns requiring a full analysis.
This is difficult to understand, given that unlike any of the other 27 projects, Coronado’s proposed project will be sited crossing one major geologic fault, and lying atop a second, each capable of producing a major earthquake. These concerns caused the Hotel del and San Diego’s Seaport Village to completely change their planned construction to avoid the same faults. The City admitted they had not considered this issue. The City’s Feasibility Study concluded that the sandy fill material under the proposed project site would be “susceptible to both liquefaction and amplified shaking in the event of a nearby earthquake.” These are exactly the types of problems that an EIR review helps a community to either avoid a problematic site, or to anticipate greatly increased construction costs to mitigate impacts, as San Diego realized when it prepared an EIR for its water reclamation project last year. Coronado does not deny the inevitable sea level rise and projected inundation during the life of the project, the obnoxious odors that result from any sewage treatment plant, nor the floodplain designation which would make the City’s planned use of low cost construction loans doubtful if they fail to perform an enhanced environmental review. If you read last week’s article in the Eagle, you also know about the scenic vista of the Bay from Glorietta Boulevard that would be blocked for residents, tourists, and golfers according to the Feasibility Report.
One major problem the City is trying to avoid is having to document whether there are reasonable alternatives to the project, as would be required under a full EIR. Under the law, a project may not be approved if feasible alternatives or mitigation measures are able to substantially lessen the significant environmental effects of the project. This is exactly the type of analysis that the City is seeking to avoid by taking an illegal shortcut in its environmental documentation. An EIR would require considerations which would mitigate the expected impacts resulting from the above issues. In addition, the EIR would require an explanation why the City did not consider alternatives, such as the pumping water from the very significant San Diego Formation aquifer underlying Coronado which the City’s 2011 water feasibility study recommended exploring. San Diego explored that option, and built a major water reclamation pumping station in Chula Vista which has the potential of producing 10 million gallons per day of water.
Our taxpayers deserve more responsibility from our Council.