CCWD - California Coastal Commission

The California Coastal Commission staff report on the El Granada Transmission Pipeline Replacement Project (144 pages, 5.2 MB file) can be reviewed at the California Coastal Commission's web site: http://www.coastal.ca.gov. It can be found on their August 6, 2003 agenda web page.

Click here to view a PDF of Board President John Muller's June 24, 2003 four-page letter plus three-page attachment to Mr. Peter Douglas, Executive Director of the California Coastal Commission, regarding the El Granada Transmission Pipeline Project. (PDF files require the Adobe Acrobat Reader – free download available.)

Letter from Terry Burnes, Planning Administrator, to Charles Lester, Deputy Director of the California Coastal Commission, regarding the pending appeal of the El Granada Pipeline Project:

May 12, 2003

Charles Lester, Deputy Director
California Coastal Commission
45 Fremont Street, Suite 2000
San Francisco, CA 94105-2219

Dear Charles:

SUBJECT: Pending appeal of Coastside County Water District’s El Granada Pipeline Project

Thank you for convening last Tuesday’s meeting on this project. Supervisor Gordon and I thought the discussion was constructive and helped to clarify the concerns of various parties and how they might be addressed. This letter is to summarize the input we provided on behalf of the County of San Mateo.

1. The County has approved this project and is aware of no information that would cause us to reconsider that position. The County believes this to be an infrastructure replacement project that does not result in additional water supplies and is not growth inducing. The sizing of the pipe is well below what would be required for planned buildout when fire flows and the district’s need to meet peak demands and have sufficient redundancy in its system are taken into account.

2. To the degree that this project would supply water to new development, it would be development planned for and authorized by our certified Local Coastal Plan. That plan, from its inception, was designed to limit residential development to those subdivision lots already in existence in 1980, when the plan was adopted. The plan does not encourage or accommodate any significant creation of new residential building sites, except on three designated affordable housing sites. We do not anticipate any change in that basic planning premise as part of the Midcoast LCP update currently underway.

3. We are in the process of recalculating buildout as part of the LCP update, to eliminate controversy over the nature and methods of those calculations. That work is being reviewed by a committee of concerned residents. Those calculations will then be transmitted to the Planning Commission this summer. In summary, and taking into account a proposed lot merger program, the projected Midcoast residential units and population at buildout under existing land use policy will most likely change from 6,200 du/14,900 residents to about 6,733 du/18,718 residents (the former calculations used a family size of 2.40, the latter 2.78, based on the 2000 census). We do not believe that these recalculated
numbers would have any effect on the justification for the pipeline project. For more information about these calculations, and related calculations of water demand and supply, please contact George Bergman of our staff at 650-363-1851.

4. The County currently has an annual growth limit for the Midcoast of 125 dwelling units. This limit is being evaluated and may be lowered as part of the LCP update project to something closer to our actual rate of growth (about 50 units per year over the past 10 years) or lower.

5. The El Granada pipeline is part of the Crystal Springs pipeline project, the major components of which were approved by the County in 1985. While the Crystal Springs project includes transmission capacity sufficient to accommodate Phase 2 water supplies, approval of that project was conditioned so as to limit it to conveyance of Phase 1 supplies only. A separate Coastal Development Permit is required if and when the District develops or obtains Phase 2 supplies, whether or not that involves actual construction of physical facilities.

6. Since the El Granada pipeline project does not involve additional water supplies and the District’s exiting supplies are fully committed, with the exception of remaining connections for priority land uses, the project cannot serve development beyond the approximately 1400 sold but unused connections that currently exist, plus the remaining approximately 500 priority connections. These are Phase 1 connections and most would be installed outside the area served by the project. I believe the District indicated that it has mapped the distribution of the sold connections. In the unincorporated area served by this project the County’s available share of priority connections would be used primarily in Princeton and Miramar or at designated affordable housing sites.

To the degree that there is concern in the community that the pipeline could be growth inducing, we believe that concern could be addressed by a clear presentation of the information above and related background on this project and its relationship to existing development and future growth.

Again, thank you for convening last week’s meeting.

Sincerely,

Terry Burnes
Planning Administrator

TB:kdr

cc: Rich Gordon, Supervisor, Third District
John Maltbie, County Manager
Tom Casey, County Counsel
Marcia Raines, Director of Environmental Services
Mike Schaller, Project Planner
Ed Schmidt, General Manager, CCWD
Dan Pincetich, City Manager, City of Half Moon Bay

Click here to view a PDF of Board President John Muller and General Manager Ed Schmidt's August 2, 2002 14-page letter to Mr. Peter Imhoff of the California Coastal Commission regarding the Consolidated El Granada Transmission Pipeline Projects. (PDF files require the Adobe Acrobat Reader – free download available.)

Director Jim Larimer's rejoinder to Mr. Coleman’s arguments in opposition to a 16-inch El Granada Pipeline, presented at the July 9, 2002 board meeting:

1. Half Moon Bay City Council did not approve a Coastal Development Permit for the El Granada pipeline.

Response: The Half Moon Bay Council’s rules state that in the event of a tied Council vote with regard to an action of the Planning Commission the recommendation of the Planning Commission will stand. A tied vote in this case was the same as a majority vote, so the Council did approve the CDP contrary to Mr. Coleman’s claim.

2. A 16-inch pipe is too large and would enable a new and unchecked development on the Coast.

Response: The data that Coleman uses to support this exaggerated claim is that a 16-inch pipe is 2.56 times larger in cross-section area than a 10-inch pipe. The ratio is correct but the conclusion that this would be growth inducing is a distortion of the facts and a simplistic analysis of the real requirements and physics of our water system. This absurd simplification has been refuted by 3 separate professional engineering analyses of the pipeline replacement project.

The three engineers who studied the El Granada renewal project and made public recommendations to the CCWD Board are James Teter, PE a long time consultant to the district; Edward Boscacci, Jr., PE, an employee of Brian, Kangas & Foulk the civil engineering firm that was hired by the San Mateo County Board of Supervisors to examine the El Granada pipeline design in response to the second appeal of the project by Carol Cupp and the LCP PAC; and Rudy Metzner, PE the engineer hired by CCWD to perform a computer simulation of the district infrastructure to evaluate and recommend for a third time an appropriate design for the El Granada pipeline. All of these Professional Engineers, all with many years of experience in designing and constructing water systems, agreed that the original Teter design was appropriate and that a 16-inch gravity flow system was required.

Mr. Metzner, PE was hired during a time when the LCP PAC slate of candidates, Carol Cupp, Eva Coleman, & Eleanor Wittrup, had the majority and control of the CCWD Board. Mr. Coleman is now disputing a recommendation made by the engineer recommended and hired by his wife during her tenure on the CCWD Board.

All of these engineering analyses and reports are available at the CCWD office and they have been widely distributed and discussed within the community. Dennis Coleman’s continuing misrepresentation of the findings made by these experienced Professional Engineers underscores his disregard for serious engineering analysis or the facts. Additionally, he infers that he is an expert on the topic of computer modeling. This assertion is made without providing any evidence of his background, training or experience in this regard. If he is an expert, then he should be forthcoming with his professional employment resume summarizing his education and experience with respect to modeling. Without objective evidence, his comments cannot be taken seriously especially in light of his disagreement with three licensed Professional Engineers each with many years of experience in designing, constructing and evaluating water systems. Mr. Metzner’s resume documents over ten years of experience in the computer modeling of water systems, one of his specialties. The assertion that an experienced bonded Professional Engineers would have intentionally or otherwise used incorrect data or assumptions to make his recommendations, as Mr. Coleman repeatedly asserts, simply is not credible.

Coleman’s core argument against the proposed design is that a 16-inch pipe is larger than needed to service CCWD. The El Granada pipeline was installed in 1947/48. At the time of installation, 54 years ago, the pipeline was more than adequate to service the community’s water distribution needs. There has been more than 50 years of development within the district during this period. The question of merit is when, what year to be specific, was the capacity of the El Granada pipeline to service the community’s water needs exceeded? This can be visualized as a graph with the year on the x-axis and the number of services on the y-axis. This graph is shown in Fig. 1.

In 1970 the El Granada pipeline reached it service capacity as a gravity flow system and a pumping station had to be added in 1971 for the El Granada pipeline to meet the service need. Gravity flow transmission systems are the most desirable engineering solution for a water system since they are failsafe during power outages caused by natural disasters such as earthquakes and fires. The El Granada pipeline had to be operated as a pumped system starting in 1971, so 1971was the year that the pipeline's ability to deliver water powered by gravity was exceeded. It has been too small since 1971.

The number of services has increased over the past 31 years from 2163 services in 1970 to 6169 today. Additionally, there are another 1900 services, 1400 of which have already been purchased, that will bring the total number of services to 8000 over the next 15 to 20 years. This rate of service connection increase is consistent with even the slowest estimates of growth, i.e., 1% in Half Moon Bay & the 80 units per year proposed in the county’s revised LCP. That represents a 370% increase in customers served from 1970 to 2022, the date at which all 8000 connections are likely to be in service. This growth will occur within the service life of a new replacement El Granada pipeline that is expected to be at least 75 years due to the improved longevity of modern pipeline materials.

By Coleman’s flawed engineering analysis, we should be proposing a 20-inch replacement pipeline to meet this need. This conclusion would be equally absurd and unrelated to best engineering practice. Engineering design is properly the domain of trained and qualified engineers and not politicians. We should adopt the recommendations of qualified professional water system engineers and replace the El Granada pipeline with a 16-inch gravity flow system. This recommendation has been confirmed by 3 independent engineering analyses of our needs.

The cost of replacing the 54-year old El Granada pipeline is approximately 4.5 million dollars if we replace it soon. Inflation will make it more expensive to replace this pipeline in the future. It has already been delayed more than 3 years.

The money to replace the pipeline is in the bank. The funds came from a combination of depreciation funds collected from current users as part of their normal water bill and from funds acquired through the purchase of Crystal Spring services. Mr. Coleman erroneously claims that the El Granada pipeline replacement is independent of the Crystal Springs project. This is not correct. Funds collected by selling new services were used to pay for the Crystal Spring Project and to partially fund the El Granada pipeline renewal.

The Crystal Springs project connected the CCWD to Hetch Hetchy and the California statewide water system. This has reduced forever our risk of loss of service due to future droughts. Droughts will certainly impact our ability to meet future demand and will likely require water conservation strategies here as elsewhere within the state. But we are now part of a statewide system with a statewide obligation to assure a supply of water to our customers.

If we undersize the El Granada replacement and must replace it again in 20 years as Mr. Coleman recommends this will cost the ratepayers another 5 million dollars within a 20 year period. These funds would have to be acquired via depreciation, an added expense to every ratepayer’s water bill of approximately 35 dollars a year every year for the next 20 years. This is a needless cost that can be avoided by simply following good engineering practice and installing the recommended 16-inch gravity flow system now.

To go beyond 8000 connections, the district would have to expand its water infrastructure. The additional costs to expand service beyond 8000 connections would be born by those future customers of the CCWD system and not by today’s ratepayers. Such a future expansion will also have to be consistent with the two LCPs that limit our community’s growth and ultimate size. To go beyond 8000 services will require new sources of water, and new Coastal Develop Permits and the CEQA process that must be followed to obtain CDPs. This is not the rapid and uncontrolled growth predicted by Mr. Coleman. It is a long, slow, open and legal process that will be driven by real future needs rather than overblown and speculative scenarios of rapid growth.

3. Coleman challenges the per capita demand data used to develop the El Granada pipeline design.

Response: The figure of merit used in the analysis is based upon historical demand data from district records. It is actual data and not an estimate. Coleman refers to average usage and ignores the critical difference between average volume and peak volume. The average volume is based every minute for an entire year. The typical residential hookup uses water only during a small fraction of that time. If you are not at home or if you are sleeping, you are probably not using water. Many Coastside residences are unoccupied for large periods of time every day. Average demand does not reflect the demand during periods when people are likely to be using water. The latter number is much larger.

The water system must be capable of providing an adequate flow of water when demand is high, for example in the morning hours and in the evening dinner hours. Sizing a system solely on average daily flow per minute would be absurd. The system must be sized to handle emergencies, for example, fire flows. Fires are more likely to occur during periods of peak demand than during periods of low demand because peak demand occurs in the same hot and dry seasons where fire risk is high.

Coleman repeatedly uses the average yearly volumes to claim excessive capacity. His comments on the sewer plant are a good example of the vacuous nature of this logic. Coleman sites average volumes of waste divided into capacity to conclude erroneously that we have too much sewage treatment capacity on the coast today. Sewer plants, however, must be sized to handle the flow volume during the rainy season. If a plant does not have sufficient storage and treatment capacity when it rains, raw untreated sewage will be dumped into the ocean. During the rainy seasons rain water runoff mixes with sewage and can overwhelm the storage capacity of the system. The posting of dangerous levels of sewage contaminants off the coast of Half Moon Bay during the rainy season is ample evidence that the coastside’s sewage treatment capacity is not adequate. A true environmentalist’s agenda would be to remedy this problem by increasing the capacity of the sewage treatment plant. Coleman and his LCP PAC associates advocate exactly the opposite just as he is now attempting to undersize the water system. He sites this absurd characterization of the sewage treatment plant as part of his argument to under-size the water system.

Under-sizing the water system puts our community at risk. Coleman’s efforts to under-size the water distribution system, if it succeeds, will result in a needless and avoidable loss of property in the future. We have already increased the risk to our community by putting off the replacement of an aging inadequate pipeline through a process of endless appeals to stop a needed infrastructure renewal project, the El Granada pipeline. Although, Coleman is not a named author of the two appeals, one by Carol Cupp and the other by Rick Lohman, he is certainly one of advocates if not the author of the language used in the appeals.

It would be a tragic lack of responsible planning by our community and the elected Board of Directors of the Coastside County Water District, if these appeals are not successfully challenged. If we are forced to under-size the system, the potentially tragic consequences of these acts should be laid directly at the feet of Mr. Coleman, Carol Cupp, Rick Lohman, their friends and backers in the LCP PAC for preventing a rational community response to a documented community need.

4. Coleman argues that more storage will fix the problem and that a 12-inch system would suffice.

Response: The water district has approximately 9 million gallons of water storage capacity today in its existing water tank facilities. This exceeds the recommended volumes for stored water for a community of our size. Adding to this capacity would add little or nothing to the margin of fire safety. The real problem is moving the water between storage tanks.

The El Granada pipeline is part of the backbone distribution system within the district. Its size limits the ability to move water from storage in the central or southern regions of the system to the northern region or visa versa. It is the impedance to a rapid recharge of storage levels from storage throughout the system, generated by an inadequately sized transmission pipeline that was one of the primary considerations in sizing the El Granada pipeline.

The pipe size impedance problem will not go away by adding more storage capacity. It will only be solved by reducing the barriers to the flow of water between storage tanks. This requires a bigger diameter pipe. A 16-inch gravity flow system will reduce the impedance between the storage tanks. They will refill more rapidly during periods of high demand if we install a 16-inch pipeline as recommended by the Professional Engineers.

Metzner found that a mixed 12/16-inch system with a new pumping station would also satisfy the flow requirements. This is a mixed system and not the 12-inch system that Mr. Coleman claims is adequate. The system would have to have a substantial 16-inch run and it would require an expensive pump.

A pumped system does not remedy as many low pressure and fire flow nodes discovered by the Metzner modeling study of the district’s system. A mixed-pipe-size-pumped-system, the only alternative with smaller sections of pipe found to be viable in the Metzner modeling analysis, would have more substandard nodes remaining after its installation than a 16-inch gravity system. A pumped system costs more to install, almost one million dollars more.

These added costs would impact the capital improvement budget possibly requiring a bond measure to pay for these additional expenses. A pumped system costs more to maintain and operate. More importantly, a pumped system is more prone to failure and will not work when there is a loss of power.

A pumped system would increase the risks within the community and reduce our ability to cope with natural disaster such as earthquakes and fires. Yet this more expensive, less adequate, fail-broken system is what Mr. Coleman and the LCP PAC favor.

Response: This is a Catch-22 argument. According to Mr. Coleman we should not improve our water infrastructure using a 50-year perspective, about two thirds of the expected service life of a new transmission pipeline, because that would put the water infrastructure ahead of the road or sewer or school infrastructure.

In a statement Mr. Coleman made on the Midcoast List in August of 2000 he says, “With nothing left to expand among the 4 pillars of a bedroom community development (sewer, water, commuter highways and schools/day care), accelerated LCP corruption, continued environmental destruction, and further loss of local economic development opportunities will be inevitable.” Mr. Coleman and his LCP PAC oppose all infrastructure improvements to schools, roads, sewers and water. All of these infrastructure elements are before our community today and sadly in need of improvements now.

Mr. Coleman’s opposition to the sewer infrastructure improvements is well known. He has recently acted in his role as City Council member to stop needed safety improvements to Hwy 92 east of Hwy 35. The county has informed Mr. Coleman and the Council that a delay on this improvement will mean that it will be pushed back at least 15 years for lack of funding. The funds to make these highway improvements are available today, but will not be available in 2 years when the funding source expires. Mr. Coleman is opposed to the Wavecrest site for the Boys and Girls Club & new middle school. The effect of this is to oppose the Boys and Girls Club and middle school. Finally, he is opposed to the recommendations of 3 independent and qualified Professional Engineers to replace an aging portion of our water system with a 16-inch gravity flow system.

We can list the infrastructure improvement projects that Mr. Coleman and his LCP PAC friends are against. Can anyone list what they are in favor of doing other than preventing one more house from being built here?

Presentation Notes concerning the El Granada, Main Street, and Carter Hill Pipeline Sizing. This presentation was given by Jim Larimer, Ph.D. and Chris Mickelsen, Directors, Coastside County Water District, at the February 27, 2002 Special Meeting of the Board of Directors: