SUPPLEMENTAL MATERIALS - Laserfiche WebLink

Aubrey Rose November 8, 2024 Page 4 The proposed project is located within the basin area under sustainable groundwater management by Zone 7 as per the Alternative Groundwater Sustainability Plan for the Livermore Valley Groundwater Basin. Thus, the proposed project would meet all applicable sustainable groundwater management actions as required. Implementation of these management impacts would ensure that groundwater quality is not impacted. (DEIR. 3.9-2.5; 3.9-2.7) This conclusion mistakes the purpose and function of the Alternative GSP. The Alternative GSP is not intended to mitigate in advance for whatever unanalyzed impact the Project may impose. Rather, sets specific regulatory thresholds for key sustainability criteria, the exceedance of which triggers intervention under SGMA. As to PFAs, the DEIR asserts that the Project will not pose a significant impact because to the extent new PFAs standards are adopted, they would be addressed “through the standing permitting and oversight processes.” This, too, mistakes the position that the Project is currently in: to the extent the Project imposes new costs and impacts on the Basin, it is the responsibility of the Project to address and mitigate for those costs. The onus is on the County, and not Zone 7, to demonstrate that the proposed Project will be in compliance with the water quality standards and thresholds set by the Alternative GSP, and will not substantially degrade groundwater quality. The DEIR does not meaningfully engage with these standards, and in the absence of that analysis cannot support its conclusion that the Project would not result in a violation of water quality standards or a substantial degradation of water quality. Zone 7 has specific and reasonable concerns about the Project’s ability to comply with these standards. For example: • The Project proposes an onsite wastewater treatment plant that would treat wastewater and then spray the effluent in an adjacent property. The onsite wastewater treatment plant is located adjacent to Lake I which is a groundwater recharge lake and could potentially be a source of surface water for drinking water in the future. The plan does not address how the solid waste will be handled from the treatment process, nor does it address the impacts of any overflows of the system adjacent to a drinking water lake. • The Project proposes spreading treated wastewater effluent in spray fields adjacent to Cope Lake. This area is at a lower elevation than the surrounding area and could be within the boundary of Cope Lake at higher water surface elevations or in flood conditions. The Water Board is currently looking at PFAS concentrations in wastewater effluent. Current wastewater treatment processes do not appear to remove PFAS and might actually increase concentrations. Treated wastewater effluent is also known to have elevated concentrations of nitrates and TDS both of which are monitored by Zone 7 under the Alternative GSP. Introduction of any of these compounds into the surface water of Cope Lake or infiltration into groundwater would be degradation of water quality.