ARCHIVED REPORTS_DRAFT ENVIRONMENTAL IMPACT REPORT

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holds slightly less affordable housing than Stanislaus and Sacramento counties. Restricting new Reverse Osmosis Treatment Alternative development in Manteca will prompt prospective home buyers—as well as retail and commercial Similar to the effluent-to-land disposal alternative discussed above,the environmental benefits of development—to look to other cities within the county,or even outside of the county,for MF/RO treatment are proportional to the incremental changes in San Joaquin River water quality affordable housing and business development opportunities. For these reasons,not seeking to that will be offset by the alternative control measure. As stated earlier,the MF/RO treatment increase WQCF discharge capacity runs contrary to the enhancement of the economic health of alternative would not improve downstream water quality in the San Joaquin River,but merely the City and surrounding communities. maintain it at pre-project levels. The projected increases in downstream receiving water Effluent-to-Land Disposal Alternative concentrations for a small collection of constituents due to the proposed 17.13 MGD(ADWF) tertiary discharge(see Table 58)are the exact same as those described for the effluent-to-land The environmental benefits of effluent-to-land application are proportional to the incremental disposal alternative. These incremental changes in downstream water quality are estimated to be changes in San Joaquin River water quality that will be offset. Projected increases in slight to moderate,thus resulting in MF/RO treatment acting to offset only slight to moderate downstream receiving water concentrations for a small number of parameters(see Table 58) reductions in San Joaquin River water quality. The more striking effects of MF/RO treatment attributable to the proposed 17.13 MGD(ADWF)tertiary discharge are generally estimated to be are found in the unfavorable environmental impacts inherent in the process resulting from brine slight to minor,thus resulting in effluent-to-land disposal acting to offset only slight to minor concentration,potential need for removal of toxic contaminants,cross-media contamination, reductions in San Joaquin River water quality. The moderate increase in downstream San brine or crystallized residuals disposal,and the substantial energy requirements of the process Joaquin River concentration,relative to its chronic EPA criterion,projected for ammonia(as with their associated natural resource and air quality impacts. nitrogen)during June through September similarly would be offset by effluent-to-land disposal. From a socio-economic perspective,MF/RO treatment is estimated to result in the loss of Land application of undisinfected,denitrified,secondary effluent would also provide an additional water supply source to the region. However,land application of secondary treated approximately 177 jobs per year during the 20-year life-cycle over which WQCF ratepayers effluent would add salts(as measured by TDS)to the groundwater basin underlying the would provide debt service for this treatment alternative. This level of employment loss is application site(s). Addition of salts to groundwater at a concentration greater than the Title 22 projected to result in an over$5.3 million annual labor income loss to the City. These losses Secondary MCL recommended level of 500 mg/L,or greater than ambient background quality, would act to further impact a local job market that is currently experiencing an unemployment would produce an unfavorable environmental impact,especially in light of the existing,elevated rate over 50 percent higher than the statewide average. In total,the cost of MF/RO treatment is salinity and boron levels found in Central Valley surface waters and groundwater. Effluent-to- estimated to result in an annual$27.2 million output loss from the local economy. This suite of land disposal also carries the risk of causing groundwater mounding in the area(s)of land impacts is the result of increased sewer fees(existing users)and connection fees(future users) application. A final unfavorable environmental impact of the effluent-to-land disposal levied against WQCF ratepayers and the associated loss of disposal personal income that is no alternative is an increase in energy consumption and air emissions due to the substantial power longer available to purchase local goods and services. Furthermore,the actual economic impact requirements of pumping effluent to storage ponds and then to land application sites. of MF/RO treatment could increase significantly above that estimated in this analysis if(1)the brine produced by the process requires additional treatment to remove heavy metals and other In regard to socio-economic impacts,the IMPLAN®model estimated that the effluent-to-land contaminants,and/or(2)brine waste requires specialized disposal in some type of hazardous disposal alternative would result in the loss of approximately 55 jobs per year during the 20-year materials containment site. To this end,the environmental and socio-economic costs associated life-cycle over which WQCF ratepayers would provide debt service for this treatment alternative. with MF/RO treatment are unduly high compared to the water quality benefits that would be This level of employment loss is projected to result in a nearly$1.7 million annual labor income achieved through the implementation of this alternative as a means of offsetting the incremental loss to the City. These losses would act to further impact a local job market that is currently water quality changes projected for the proposed project. For these reasons,it is not in the public experiencing an unemployment rate over 50 percent higher than the statewide average. In total, interest to require the City to implement MF/RO treatment of its effluent to maintain existing the cost of effluent-to-land disposal is estimated to result in an annual$8.5 million output loss water quality in the San Joaquin River. from the local economy. This suite of impacts is the result of increased sewer fees(existing users)and connection fees(fixture users)levied against WQCF ratepayers and the associated loss Proposed Project of disposal personal income that is no longer available to purchase local goods and services. The water quality impacts analysis conducted earlier in this report shows that WQCF effluent Furthermore,the actual economic impact of effluent-to-land disposal could increase significantly undergoing nitrification-denitrification,tertiary filtration,and UV disinfection will generally above that estimated in this analysis if the City was required to provide tertiary filtration of its result in water of very high quality being discharged by the City into the San Joaquin River. As effluent prior to land application. To this end,the environmental and socio-economic costs shown in Table 58,de minimis decreases in the downstream concentrations of TSS,total associated with effluent-to-land disposal are unduly high compared to the water quality benefits aluminum,dissolved iron,dissolved manganese are projected,while slight to minor increases are that would be achieved through the implementation of this alternative as a means of offsetting estimated for ammonia as N(October through May),dissolved arsenic,dissolved copper,total the incremental water quality changes projected for the proposed project. For these reasons,it is cyanide,MBAS,nitrate,nitrite,total mercury,BOD,and EC. A moderate increase in not in the public interest to require the City to implement effluent-to-land disposal as a means of downstream San Joaquin River concentration,relative to its chronic EPA criterion,is projected maintaining existing water quality in the San Joaquin River. for ammonia as N during the months of June through September. However,this near-field, City of Manteca Antidegradation Analysis 117 June 2007 City of Manteca Antidegradation Analysis 118 June 2007