Escondido is considering placing a reverse osmosis filtration and treatment plant on a vacant lot. The lot sits next to a senior residential facility and low-income housing.
By Don Greene / djgreene.net
Monday, December 13, the Escondido Planning Commission continued its unbelievable policy of “Making Escondido the 50s Again” and approved a Reverse Osmosis/Membrane Filtration plant for the corner of Ash(Route 78) and Washington. How – you might ask – does adding something which is the future of water preservation make Escondido “the 50s” again? One of the major justification of putting this very industrial use in a very residential neighborhood was: this used to be the location of the water department.
Of course, back then, the water department was surrounded by fruit trees and mice. Now, the location sits smack dab in the middle of a highly residential area; a 100-unit Senior living facility adjacent to the east, a row of affordable housing directly to the north and commercial/retail on the remaining sides, along with the Escondido Creek adjacent to the south.
The purpose of the plant is to further clarify treated recycled water for agricultural use. An amazing product which will help farmers and the other residents of Escondido by reducing our reliance on imported water and reduce the amount of water which is sent through our outfall into the ocean. (The outfall is a pipe which runs from our treatment facility on Hale Avenue, under the Escondido Creek, to the ocean.) The reduction in water sent to the ocean is critical because we are close to the capacity of the pipe and replacing it would be close to a billion dollars.
So why is this project bad?
The property located in the graphic above, taken from the staff report, is currently zoned CG, which is General Commercial. Great place for a mixed-used (retail and residential) project or just strictly a retail/commercial use. And, it’s currently zoned for that particular use. The city, instead, wants to put an industrial grade project on the spot and is justified in doing so because of our antiquated zoning ordinance which allows utility uses on CG zoned land. In fact, on Monday evening, the city was asking for the approval of a CUP (Conditional Use Permit). By the very definition of a CUP, we know and understand the project does not fit the location.
Go back a year or so and we can hear a very similar tale about this same project. The Utilities Department wanted to place this facility on a patch of land at El Norte Pkwy and Washington. They were thwarted from placing the project at this location because the neighborhood came together and rejected it. The destruction of property values was too great and this appears to be the only threat this commission (and by extension council) seems to understand. Fast forward to last Monday, and the Planning Commission was not in the least bit worried about the placement of this project on this plot because a Senior living facility and affordable housing don’t bring the same level of threat that angry home owners do.
Combine the lack of threat with the city’s favorite tool to bypass the law – the Mitigated Negative Declaration – and we have the perfect storm which is going to plop tens of thousands of gallons of chemicals in the middle of a dense residential area. More on this in a bit. The MND (Mitigated Negative Declaration) is a tool used by planning departments to circumvent the California Environmental Quality Act (CEQA) which governs development and land use. CEQA requires impacts to be studied when new development of any type happens. An MND can be used to declare impacts are “less than significant” and thereby, bypass the more stringent requirements of CEQA which would be an Environment Impact Review (EIR). Still with me? Good.
Ordinarily, an MND would be acceptable if, in fact, all impacts are deemed “less than significant.” But there’s a technicality in CEQA – found in California Public Resources Code at Section 21002 – which reads in part “[P]ublic agencies should not approve projects as proposed if there are feasible alternatives…” Feasible alternatives. The problem with the City bypassing the CEQA required EIR is there is a feasible alternative.
This project needs to run along the Escondido Creek. It is there the City chose to run its recycled water lines and, since this facility is for the further treatment of recycled water, the proximity to the existing lines is important. If you follow the Escondido Creek “upstream” or back toward the HARRF (Hale Avenue Resource Recovery Facility), you will find a very large, almost 12 acre site known as the Public Works yard. The City could very easily place this project within the Public Works yard area and not burden the neighbors with this project. The works yard is zoned for industrial use and we would be able to put a project where its intended to go, instead of using a CUP to make it fit.
But, the City wouldn’t consider it. I raised this point to the Planning Commission and they talked about everything else except the Public Works yard. Why? Four words: Mayor Sam’s Business Park. The works yard sits in the area Abed continues to earmark for the monument to his greatness: The Crossroads Business Park. So, to protect his legacy he has chosen to endanger seniors and low-income residents.
This project proposes to house tens of thousands of gallons of chemicals with which the plant will further treat the water. Sodium hypoclorite, liquid ammonium sulfate, sulfuric acid, sodium bisulfite, sodium hydroxide, and calcium chloride are the named chemicals. There are others which are listed by their duties – antiscalant, proprietary RO base, etc – which we don’t know. Tens of thousands of gallons of these chemicals will sit in the residential neighborhood, next to a senior living facility which often has sick and otherwise health fragile residents.
The City guarantees the facility will be safe and nothing will happen. Just like the City guaranteed nothing would happen at its Water Treatment plant at Lake Dixon. Unfortunately the plant did experience a 30,000 gallon spill of sodium hydroxide (remember this from the previous list) when the tank storing the chemical failed and ruptured. The spill not only filled the containment area, but leaked out and contaminated a large area of the canyon behind Dixon Dam which a hazmat team cleaned.
If the same type of spill were to happen here, the chemical would not only be in the containment area, but could potentially spill out into the Escondido Creek and contaminate the waters. We could be completely unaware of a spill happening. First because the Utility Department is not going to staff the facility so a tank failure would happen and we could only react after the fact and second, because we’re going to bury some of the tanks at the proposed site to make it more visually appealing to the surrounding neighborhood. Again, because it’s not the right place for this use. If we had this plant in the Public Works Yard, we could build the right type of containment, divert everything away from the creek and avert a much more serious problem by having staff on site to react more quickly.
There are a number of problems with this project which the Planning Commission just didn’t seem to care about. There was a false dichotomy presented to them by City staff which gave them the choice of doing the project and saving farmers and residents money, or choose the more costly billion dollar option of expanding the outfall. And, with the lack of proper studies, it appeared this was their only choice. No one at the hearing was opposed to the project, just its location.
We must demand a full EIR be done so all feasible options are explored. Utilities Director McKinney told me the works yard cannot be used because the Utility Department did not own the land. This is poppycock. City’s are able to swap land owned by an enterprise fund and the general fund. Whether they are willing to do it is another thing all together. It seems our city was willing to swap the location of this project once when more affluent residents complained. But apparently seniors and low-income residents are worth the effort.
Don Greene is the former North Area Vice Chair for the San Diego County Democratic Party and remains on the party’s Central Committee. He is currently the Aide to the Deputy Mayor of Oceanside and has consulted on a number of local campaigns. All opinions expressed by Don are his own and not necessarily those of his employer or his clients.