1.                   Regarding “free water”, you need to realize that this is secondary sewage effluent, not potable water.  There are strict regulations on the level of wastewater treatment required depending upon the use of the effluent.  Currently, the effluent is percolated into the groundwater using ponds known as “rapid infiltration basins.”  This type of discharge requires treatment to a “secondary level”, which is achieved through treatment ponds at the plant.  No disinfection of the wastewater is required, and dangerous levels of bacteria may be present in the water.  This level of treatment is only suitable for discharge to the groundwater, and is not sufficient for even discharge to the Bar One for pasture irrigation.  The Loyalton rapid infiltration basins do not work in very wet years, resulting in excess treated wastewater, or effluent.  For the City to discharge to Bar One, where it is used for pasture irrigation, it must be chlorinated, the rancher must prevent access from the public, and he must provide buffer zones to the property lines.  For the City to use this effluent on a park or the school property, they would have to build a sophisticated filtration plant at a cost in excess of $2 Million, not counting the pipelines needed to convey the water to an irrigation site, or the operating cost of the new treatment plant.

2.                   Regarding the existing discharge to Bar One, this discharge was initiated by the City in 2000 as a response to the excess effluent in the disposal ponds.  During a period where the City’s ponds were overflowing, as a favor to the City, the Bar One agreed to accept the effluent for irrigation.  In order for the discharge to Bar One to be legal, the Loyalton treatment plant discharge permit was modified, and a new discharge permit was issued to Bar One to allow use of the wastewater.  Both permits limit the discharge to Bar One to between March 15 and November 1.  Unfortunately the winter period between November and March 15 is the exact time during which the City’s ponds have trouble getting rid of the effluent.  This is the reason the new treatment plant expansion includes the construction of large lined storage ponds to hold the effluent during the winter.

3.                   The effluent irrigation with Bar One was handled under an agreement with Jack Sparrowk dba Sierra Valley Ranch, which was signed in 2002 and expired in 2007.  The agreement has not been renewed, and no request for renewal was received from Bar One.  The City has not supplied effluent to Bar One since 2007.

4.                   In 2002, the owners of the Bar One Ranch put the ranch into a conservation easement that prevents additional development on the property.  This development restriction prohibits the ranch increasing agricultural activities, including increasing the amount or manner of effluent irrigation.  Since the City needs to approximately double the amount of irrigation from what Bar One received, the Bar One cannot therefore receive all the water that the City needs to dispose of.  We could split the water half and half with another site, but the permitting and monitoring requirements on the City’s behalf are expensive and require ongoing testing.  We do not want to monitor two different sites.  The Bar One used the water for flood irrigation, and their irrigation site does not comply with the newest requirements for monitoring wells and runoff recovery.  To continue discharging to the Bar One, the City would need to construct these improvements, which are probably prohibited by the conservation easement.

5.                   In the facility plan that ECO:LOGIC prepared for the wastewater expansion, we looked into several sites for the effluent disposal.  These included the Bar One, Carl Genasci’s property, and Einen Grandi’s property.  The least cost to the City for disposal of all of the effluent is the proposed Grandi parcel directly north of the treatment plant.  We have an environmental requirement to minimize disturbances to existing farmed property, and the parcel we have identified is not currently irrigated or actively farmed.  This is a distinct advantage.  The next question was whether we would need to purchase the land or whether it could be leased, thus saving the City the cost of land acquisition.  We would expect that farm land purchase could exceed $3,000 per acre, or $300,000 for the approximately 100 acres we would need.  As an alternative, Rural Development indicated that we can lease the land, as long as we have a minimum 20 year agreement. 

6.                   Our current proposal is to lease approximately 100 acres from Einen Grandi for approximately $150,000 to $175,000.  A draft agreement has been prepared, but has not been acted upon by either Grandi or the City.  This agreement has been prepared by ECO:LOGIC on behalf of the City, and has been reviewed briefly by the City’s attorney.  No members of the City Council have been involved in either the preparation or negotiations, nor have they been present during any of my discussions with Mr. Grandi.  The lease payment is proposed to be a single payment up front, with no recurring payments during the life of the lease.  In return for this payment, Grandi agrees to accept all the City’s wastewater for the next 20 years, and for 5 year increments thereafter unless notice is given that the lease will be terminated.  No restrictions are placed on what Mr. Grandi does with the lease money; however, he intends to construct a center pivot irrigation system on the parcel.  The electrical cost of pumping the effluent over to the irrigation site would be split 50/50 between Mr. Grandi and the City.  If the City were to purchase the land outright, they would also have to purchase the irrigation equipment and operate and maintain it.  Thus the use of the lease arrangement is approximately $250,000 less expensive than a direct purchase, not counting the additional personnel needed to operate the irrigation equipment.

7.                   I am not opposed to considering Mr. Genasci’s property, however it is already being farmed, which is a concern, and is a smaller parcel that is not as conducive to a center pivot irrigation system.  This parcel will have higher costs associated with monitoring wells, runoff recovery, and irrigation equipment.

8.                   As part of the proposed agreement, the City will be paying the annual discharge permit fee for the irrigation parcel, as well as installing and testing the monitoring wells.  This is an annual cost that Mr. Grandi would want to have paid by the City if we were to require him to perform it.  Since the City already has a sample pump and performs similar sampling on their three existing monitoring wells, the sampling would be an inexpensive task for City staff to perform.

I hope this helps to clarify a few issues. Please do not hesitate to call me at 775-689-0108 if you have any questions.

Ray Kruth, P.E.